Privacy Policy

1) Introduction and contact details of the responsible party

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 is any data that can be used to personally identify you.

1.2 The controller responsible for data processing on this website within the meaning of the General Data Protection Regulation (GDPR) is

EP EURO POOL GmbH
c/o Secret Brands Akazienweg 1a 99195 Riethnordhausen , E-Mail: kundenservice@smilesecret.de. The controller responsible for processing 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 When you use our website for purely informational purposes, 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/referrer from which you accessed this page
• Browser used
• Operating system used
• IP address used (possibly in anonymized form)

The processing is carried out in accordance with Article 6(1)(f) GDPR on the basis of our legitimate interest in improving the stability and functionality of our website. The data will not be disclosed or used for any other purpose. However, we reserve the right to subsequently review the server log files should there be concrete indications of unlawful use.

2.2 This website uses SSL or TLS encryption for security reasons and to protect the transmission of personal data and other confidential content (e.g., orders or inquiries to the data controller). You can recognize an encrypted connection by the "https://" prefix and the padlock symbol in your browser's address bar.

3) Hosting & Content Delivery Network

For hosting our website and displaying the page content, we use a provider that performs its services itself or through selected subcontractors exclusively on servers within the European Union.

All data collected on our website is processed on these servers.

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.

4) Cookies

To make your visit to our website more enjoyable and to enable the use of certain features, we use cookies, which are small text files that are stored on your device. Some of these cookies are automatically deleted after you close your browser (so-called "session cookies"), while others remain on your device for a longer period and allow us to save your website settings (so-called "persistent cookies"). In the latter case, you can find information about the storage duration in your web browser's cookie settings.

If any of the cookies we use process personal data, this processing is carried out in accordance with Art. 6 para. 1 lit. b GDPR either for the performance of the contract, in accordance with Art. 6 para. 1 lit. a GDPR in the case of consent given, or in accordance with Art. 6 para. 1 lit. f GDPR to safeguard our legitimate interests in the best possible functionality of the website and a customer-friendly and effective design of the website visit.

You can configure your browser to notify you when cookies are set and allow you to decide whether to accept them individually, or to exclude the acceptance of cookies in certain cases or entirely.

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

5) Making contact

When you contact us (e.g. via contact form or email), personal data is processed – exclusively for the purpose of processing and responding to your request and only to the extent necessary.

The legal basis for processing this data is our legitimate interest in responding to your inquiry pursuant to Article 6(1)(f) GDPR. If your contact is aimed at a contract, the additional legal basis for processing is Article 6(1)(b) GDPR. Your data will be deleted when it is clear from the circumstances that the matter has been resolved and provided that no statutory retention obligations apply.

6) Use of customer data for direct marketing

6.1 Registration for our email newsletter

When you subscribe to our email newsletter, we will regularly send you information about our offers. The only mandatory information required to send you the newsletter is your email address. Providing any further information is voluntary and is used to personalize our communications with you. We use the double opt-in procedure for newsletter distribution, which ensures that you only receive newsletters after you have explicitly confirmed your consent to receive them by clicking a verification link sent to the email address you provided.

By activating the confirmation link, you give us your consent to use your personal data in accordance with Article 6 Paragraph 1 Letter a of the GDPR. We store your IP address, which is registered by your Internet Service Provider (ISP), as well as the date and time of registration, in order to be able to trace any potential misuse of your email address at a later date. The data we collect when you subscribe to the newsletter is used strictly for the intended purpose.

You can unsubscribe from the newsletter at any time via the link provided in the newsletter or by sending a message to the data controller named above. After unsubscribing, your email address will be immediately deleted from our newsletter mailing list, unless you have expressly consented to further use of your data or we reserve the right to use your data for other purposes permitted by law, which we will inform you about in this privacy policy.

6.2 Sending the email newsletter to existing customers

If you provided us with your email address when purchasing goods or services, we reserve the right to regularly send you offers for similar goods or services from our product range via email. According to Section 7 Paragraph 3 of the German Unfair Competition Act (UWG), we do not need to obtain your separate consent for this. The data processing is based solely on our legitimate interest in personalized direct marketing pursuant to Article 6 Paragraph 1 Letter f of the GDPR. If you initially objected to the use of your email address for this purpose, we will not send you any emails.

You have the right to object to the use of your email address for the aforementioned advertising purpose at any time with effect for the future by sending a message to the data controller named at the beginning of this document. You will only incur transmission costs at the basic rates for this. Upon receipt of your objection, the use of your email address for advertising purposes will be discontinued immediately.

6.3 Klaviyo

Our email newsletters are sent via this provider: Klaviyo, Inc., 125 Summer St., Ste 600, Boston, MA 02110, USA

Based on our legitimate interest in effective and user-friendly newsletter marketing, we pass on the data you provided when registering for the newsletter to this provider in accordance with Art. 6 para. 1 lit. f GDPR, so that they can take over the newsletter distribution on our behalf.

Subject to your explicit consent pursuant to Art. 6 para. 1 lit. a GDPR, the provider also conducts statistical performance analysis of newsletter campaigns using web beacons or tracking pixels in the sent emails, which can measure open rates and specific interactions with the newsletter content. Device information (e.g., time of access, IP address, browser type, and operating system) is also collected and analyzed, but not combined with other data sets.

You can revoke your consent to newsletter tracking at any time with effect for the future.

We have concluded a data processing agreement with the provider, which protects the data of our website visitors and prohibits its transfer to third parties.

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

6.4 Shopping cart reminders via email

If you cancel your purchase with us before completing your order, you have the option of receiving a one-time email reminder about the contents of your virtual shopping cart.

The only mandatory information required to send you this reminder is your email address. Providing further information is voluntary and may be used to personalize our communications with you. We use a double opt-in procedure for sending emails, which ensures that you only receive a notification after you have explicitly confirmed your consent by clicking a verification link sent to the specified email address.

By activating the confirmation link, you give us your consent to use your personal data in accordance with Article 6 Paragraph 1 Letter a of the GDPR for sending you a shopping cart reminder. We store your IP address, registered by your Internet Service Provider (ISP), as well as the date and time of registration, in order to be able to trace any potential misuse of your email address at a later date. The data we collect when you register for our email notification service is used strictly for this purpose.

You can unsubscribe from shopping cart reminders at any time by sending a message to the responsible party mentioned above. After unsubscribing, your email address will be immediately deleted from our mailing list, unless you have expressly consented to further use of your data or we reserve the right to use your data beyond this scope, which is permitted by law and about which we inform you in this statement.

7) Data processing for order processing

7.1 Insofar as necessary for the processing of the contract for delivery and payment purposes, the personal data we collect will be passed on to the commissioned transport company and the commissioned credit institution in accordance with Art. 6 para. 1 lit. b GDPR.

If we owe you updates for goods with digital elements or for digital products based on a corresponding contract, we process the contact details you provided when placing your order in order to inform you personally in accordance with our legal information obligations pursuant to Art. 6 para. 1 lit. c GDPR. Your contact details will be used strictly for the purpose of notifying you about updates we owe you 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 fulfilling concluded contracts. Certain personal data will be transmitted to these service providers in accordance with the following information.

7.2 JTL

We use the following provider for order processing: JTL-Software-GmbH, Rheinstr. 7, 41836 Hückelhoven, Germany

Your name, address, and any other personal data will be forwarded to the provider in accordance with Article 6 Paragraph 1 Letter b of the GDPR solely for the purpose of processing your online order. Your data will only be shared to the extent that this is actually necessary for processing the order.

7.3 Transfer of personal data to shipping service providers

- DHL

We use the following provider as our transport service provider:

General Logistics Systems
Germany GmbH & Co. OHG
GLS Germany-Straße 1 - 7
DE-36286 Neuenstein

We will forward your email address and/or telephone number to the supplier before delivery of the goods in accordance with Article 6 Paragraph 1 Letter a of the GDPR for the purpose of coordinating a delivery date or announcing the delivery, provided you have given your express consent during the ordering process. Otherwise, for the purpose of delivery in accordance with Article 6 Paragraph 1 Letter b of the GDPR, we will only forward the recipient's name and delivery address to the supplier. This data is only shared to the extent necessary for the delivery of the goods. In this case, prior coordination of the delivery date with the supplier or delivery notification is not possible.

Consent can be withdrawn at any time with effect for the future by contacting the controller named above or the provider.

7.4 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

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

When selecting a payment method where we make advance payments, you will also be asked to provide certain personal data during the ordering process (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).

In order to protect our legitimate interest in assessing your creditworthiness in such cases, we forward this data to the provider for the purpose of a credit check in accordance with Article 6(1)(f) GDPR. Based on the personal data you provide, as well as other data (such as shopping cart contents, invoice amount, order history, and payment history), the provider checks whether the payment option you have selected can be granted with regard to payment and/or default risks.

The credit report may contain probability values ​​(so-called score values). If score values ​​are included in the credit report, they are based on a scientifically recognized mathematical-statistical method. Address data is among the factors, but not the only one, used in calculating the score values.

You can object to this processing of your data at any time by sending a message to us or to the provider. However, the provider may still be entitled to process your personal data if this is necessary for processing payments in accordance with the contract.
- 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

When you select a payment method from the provider that requires you to pay in advance (such as credit card payment), your payment details provided during the ordering process (including name, address, bank and payment card information, currency, and transaction number), as well as information about the contents of your order, will be transmitted to the provider in accordance with Article 6 Paragraph 1 Letter b GDPR. In this case, your data will be transmitted exclusively for the purpose of processing the payment with the provider and only to the extent necessary for this purpose.

8) Retargeting/remarketing and conversion tracking

Meta Pixel with extended data matching

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

When a user clicks on one of our ads on Facebook or Instagram, the URL of our linked page is extended with a parameter using "Meta 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 collects specific customer data, such as the email address, which we collect on our website linked to the Facebook or Instagram ad during processes like purchases, account logins, or registrations (extended matching). The cookie is then read and enables the transmission of the data, including the specific customer data, to Meta.

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

Furthermore, we analyze the effectiveness of our advertisements by tracking whether users were redirected to our website after clicking on an ad (conversion). Compared to the standard "Meta Pixel" feature, the enhanced matching function helps us better measure the effectiveness of our advertising campaigns by capturing more attributed conversions.

All transmitted data is stored and processed by Meta, so that it can be associated with the respective user profile and Meta can use the data for its own advertising purposes in accordance with Meta's data usage policy ( https://www.facebook.com/about/privacy/). ) can use the data. This data can enable Meta and its partners to display ads on and off 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 explicit consent in accordance with Art. 6 para. 1 lit. a GDPR. You can revoke your consent at any time with effect for the future 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 Meta is usually transferred to and stored on a Meta server; in this context, data may also be transferred to servers of Meta Platforms Inc. in the USA.

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

9) Rights of the data subject

9.1 The applicable data protection law grants you the following rights as a data subject (rights of access 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 of access pursuant to Art. 15 GDPR;
• Right to rectification pursuant to Article 16 GDPR;
• Right to erasure pursuant to Article 17 GDPR;
• Right to restriction of processing pursuant to Article 18 GDPR;
• Right to information pursuant to Article 19 GDPR;
• Right to data portability pursuant to Art. 20 GDPR;
• Right to withdraw consent pursuant to Art. 7 para. 3 GDPR;
• Right to lodge a complaint pursuant to Article 77 GDPR.

9.2 Right of objection

If we process your personal data based on our overriding legitimate interest as part of a balancing of interests, you have the right to object to this processing at any time, on grounds relating to your particular situation, with effect for the future.

If you exercise your right to object, we will cease processing the data in question. However, further processing remains possible if we can demonstrate compelling legitimate grounds for the processing which override your interests, fundamental rights and freedoms, or if the processing serves the purpose of establishing, exercising or defending 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. You can exercise your right to object as described above.

If you exercise your right to object, we will cease processing the data in question for direct marketing purposes.

10) Duration of storage of personal data

The duration of the storage of personal data is determined by the respective legal basis, the purpose of processing and – if applicable – additionally by the respective statutory retention period (e.g. commercial and tax law retention periods).

When processing personal data on the basis of explicit consent pursuant to Art. 6 para. 1 lit. a GDPR, the data concerned will be stored until you withdraw your consent.

If statutory retention periods exist for data processed in the context of contractual or quasi-contractual obligations on the basis of Art. 6 para. 1 lit. b GDPR, this data will be routinely deleted after the expiry of the retention periods, provided that it is no longer required for the performance of a contract or for initiating a contract and/or we no longer have a legitimate interest in its continued storage.

When processing personal data on the basis of Article 6(1)(f) GDPR, this data will be stored until you exercise your right to object pursuant to Article 21(1) GDPR, unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves the purpose of establishing, exercising or defending legal claims.

When processing personal data for direct marketing purposes on the basis of Art. 6 para. 1 lit. f GDPR, this data will be stored until you exercise your right to object pursuant to Art. 21 para. 2 GDPR.

Unless otherwise stated in the other information in this declaration regarding specific processing situations, stored personal data will be deleted when it is no longer necessary for the purposes for which it was collected or otherwise processed.