This Privacy Policy ("Policy") describes the information that JHT Company GmbH ("Cuff Copenhagen," "we," "us," or "our") collects, how we use this information, and the options you have to access, correct, or delete it.

OVERVIEW:

• 1. Collection and storage of personal data and the nature and purpose of their use

• 2. Disclosure of personal data

• 3. Your rights regarding your personal data

• 4. Duration of data storage

• 5. Cookies

• 6. Online marketing / analytics tools

• 7. Newsletter

• 8. Social media plugins

• 9. Integration of third-party services and content

• 10. Data security

• 11. Updating and changing this privacy policy

• 12. Name and contact details of the data controller

PRIVACY POLICY

We welcome your visit to our website www.cuffcph.com and your interest in our company and offerings. For external links to third-party content, we assume no liability, as we have not initiated the transmission of this information, selected the recipient of the transmitted information, or altered the transmitted information itself.

The protection of your personal data during the collection, processing, and use of it during your visit to our websites is important to us and is carried out in accordance with legal regulations.

In the following, we will explain to you what information we collect during your visit to our websites and how it is used:

1. COLLECTION AND STORAGE OF PERSONAL DATA AND THE NATURE AND PURPOSE OF THEIR USE

A) WHEN VISITING THE WEBSITE

Whenever a customer (or other visitor) accesses our website, information is automatically sent to the server of our website by the internet browser used on your end device (computer, laptop, tablet, smartphone, etc.). This information is temporarily stored in a so-called log file.

The following data is collected without your intervention and stored until automatic deletion:

• IP address of the requesting computer, as well as device ID or individual device identifier and device type
• Name of the requested file and transmitted data volume, as well as date and time of the access
• Report on successful access
• Requesting domain
• Description of the type of internet browser used and, if applicable, the operating system of your end device, as well as the name of your access provider
• Your browser history data as well as your standard web log information, location data, including location data from your mobile device. Please note that on most mobile devices, you can control or disable the use of location services in the device's settings.

Our legitimate interest pursuant to Art. 6 (1) sentence 1 lit. f GDPR for collecting the data is based on the following purposes:

• Ensuring smooth establishment of a connection and comfortable use of the website
• Evaluation of system security and stability
• For other administrative purposes

In no case do we use the collected data for the purpose of drawing conclusions about your person.

B) WHEN USING OUR CONTACT FORM

For inquiries of any kind, we offer you the opportunity to contact us via a form provided on the website. At least a valid email address and your name are required so that we know who the inquiry is from and can respond to it. Further information can be provided voluntarily.

The data processing for the purpose of contacting us is carried out in accordance with Art. 6 (1) sentence 1 lit. a GDPR based on your voluntarily given consent.

The personal data collected by us for the use of the contact form will be automatically deleted after the inquiry you have made has been dealt with.

C) WHEN CONCLUDING A CONTRACTUAL RELATIONSHIP

When concluding a contractual relationship on our website (e.g., registration on the website/platform, purchase in our online shop), we ask you for the following personal data:

• Data that personally identifies you such as name and email address, billing and shipping address, and telephone number
• If applicable, academic title
• Data that identifies your company, such as company name, address, communication data (email address, telephone and fax number), VAT ID or tax number
• Information about your payment method
• Other personal data that we are legally obliged or entitled to collect and process, and that we need for your authentication, identification, or to verify the data we have collected.

The data mentioned above are processed for the purpose of executing the contractual relationship and, if necessary, will be passed on to the transport company commissioned with the delivery. The data processing is carried out on the basis of Art. 6 (1) lit. b GDPR. The storage period is limited to the purpose of the contract and, if applicable, legal and contractual retention obligations.

D) USE OF PAYMENT SERVICE PROVIDERS 

To process your order, we also work with the following payment service providers. We forward your payment data as part of the payment process - as required for payment processing - to the authorized credit institution. The following payment service providers can be selected for payment. The legal basis for data transfer is Art. 6 (1) lit. b GDPR.

List of payment service providers:

• Stripe; Stripe's Privacy Policy
• PayPal; PayPal's Privacy Policy
• Klarna; Klarna's Privacy Policy
• Visa; Visa's Privacy Policy
• Mastercard; Mastercard's Privacy Policy

E) WHEN SUBSCRIBING TO OUR NEWSLETTER

If you have expressly consented in accordance with Art. 6 (1) sentence 1 lit. a GDPR, we will use your email address to send you our newsletter on a regular basis. Unsubscribing is possible at any time, for example, via a link at the end of a newsletter. Alternatively, you can also send your unsubscribe request to support@cuffcph.com by email (preferably with the subject: "Unsubscribe Newsletter").

2. DISCLOSURE OF PERSONAL DATA

Transfer of your data to third parties for purposes other than those listed below does not take place. We only share your data with third parties if:

• You have given explicit consent to do so in accordance with Art. 6 (1) sentence 1 lit. a GDPR
• It is necessary for the performance of contracts with you in accordance with Art. 6 (1) sentence 1 lit. b GDPR
• There is a legal obligation to disclose the data in accordance with Art. 6 (1) sentence 1 lit. c GDPR
• The disclosure is necessary to assert, exercise, or defend legal claims and there is no reason to believe that you have an overriding legitimate interest in not disclosing your data in accordance with Art. 6 (1) sentence 1 lit. f GDPR

In these cases, the scope of the data transmitted is limited to the minimum necessary.

Our privacy policy is in accordance with the applicable data protection regulations.

3. YOUR RIGHTS REGARDING YOUR PERSONAL DATA

Upon request, we will be happy to inform you about whether and which personal data about you is stored (Art. 15 GDPR), in particular about the processing purposes, the category of personal data, the categories of recipients to whom your data has been or will be disclosed, the planned storage period, the existence of a right to correction, deletion, restriction of processing, or objection, the existence of a right to complain, the origin of your data if it was not collected by us, and the existence of automated decision-making, including profiling, and, if applicable, meaningful information about their details.

A) RIGHT TO CORRECTION In accordance with Art. 16 GDPR, you have the right to request the correction of incorrect or incomplete personal data stored by us without delay.

B) RIGHT TO DELETION ("RIGHT TO BE FORGOTTEN") In accordance with Art. 17 GDPR, you have the right to request the deletion of your personal data stored by us, provided that the processing is not necessary to exercise the right to freedom of expression and information, to fulfill a legal obligation, for reasons of public interest or to assert, exercise, or defend legal claims.

C) RIGHT TO RESTRICTION OF PROCESSING In accordance with Art. 18 GDPR, you have the right to request the restriction of the processing of your personal data if you dispute the accuracy of the data, the processing is unlawful, but you refuse to delete it, and we no longer need the data, but you need it to assert, exercise, or defend legal claims, or you have objected to the processing in accordance with Art. 21 GDPR.

D) RIGHT TO DATA PORTABILITY In accordance with Art. 20 GDPR, you have the right to receive your personal data that you have provided to us in a structured, common, and machine-readable format or to request its transmission to another person responsible.

E) RIGHT TO OBJECT In accordance with Art. 21 GDPR, you have the right to object at any time to the processing of your personal data for reasons arising from your particular situation, provided that data processing is carried out on the basis of legitimate interests (Art. 6 (1) sentence 1 lit. f GDPR) and there are no compelling legitimate reasons for the processing on our part, or the processing serves to assert, exercise, or defend legal claims.

F) RIGHT TO WITHDRAW CONSENT In accordance with Art. 7 (3) GDPR, you have the right to withdraw your consent at any time. As a result, we are no longer allowed to continue the data processing based on this consent for the future.

G) RIGHT TO COMPLAIN In accordance with Art. 77 GDPR, you have the right to lodge a complaint with a supervisory authority if you believe that the processing of your personal data violates data protection regulations. This applies in particular to the supervisory authority in the Member State of your place of residence, your place of work, or the place of the alleged violation.

4. DURATION OF DATA STORAGE

We adhere to the principles of data avoidance and data economy. We therefore only store your personal data for as long as is necessary to achieve the purposes stated here or as provided for by the various storage periods provided for by law. After the respective purpose ceases to exist or after these deadlines have expired, the corresponding data will be blocked or deleted as a matter of routine and in accordance with statutory regulations.

5. COOKIES

We use cookies on our site. These are small files that your browser automatically creates and that are stored on your device (laptop, tablet, smartphone, etc.) when you visit our site. Cookies do not harm your device, do not contain viruses, Trojans, or other malware.

Information is stored in the cookie that results in each case in connection with the specifically used terminal device. However, this does not mean that we become immediately aware of your identity.

The use of cookies serves, on the one hand, to make the use of our offer more pleasant for you. For example, we use so-called session cookies to recognize that you have already visited individual pages on our website. These are automatically deleted after leaving our site.

In addition, we also use temporary cookies that are stored on your device for a specified period of time to optimize user-friendliness. If you visit our site again to use our services, it will automatically recognize that you have already been with us and what entries and settings you have made so that you do not have to enter them again.

On the other hand, we use cookies to statistically record the use of our website and to evaluate it for the purpose of optimizing our offer for you. These cookies enable us to automatically recognize when you visit our site again that you have already been with us. These cookies are automatically deleted after a defined period of time.

The data processed by cookies are required for the above-mentioned purposes to safeguard our legitimate interests and those of third parties pursuant to Art. 6 (1) sentence 1 lit. f GDPR.

Most browsers accept cookies automatically. However, you can configure your browser so that no cookies are stored on your computer or so that a message always appears before a new cookie is created. However, the complete deactivation of cookies can lead to the fact that you cannot use all the functions of our website.

6. ONLINE MARKETING / ANALYTICS TOOLS

a) GOOGLE ANALYTICS

For the purpose of demand-oriented design and continuous optimization of our pages, we use Google Analytics, a web analysis service provided by Google Inc. (https://www.google.de/intl/de/about/) (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, hereinafter referred to as "Google"). In this context, pseudonymized usage profiles are created and cookies (see point 5) are used. The information generated by the cookie about your use of this website, such as

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

are transferred to a Google server in the USA and stored there. The information is used to evaluate the use of the website, to compile reports on the website activities, and to provide further services associated with the use of the website and the internet for the purposes of market research and demand-oriented design of these internet pages. This information may also be transferred to third parties if this is required by law or if third parties process this data on behalf of the company. Under no circumstances will your IP address be merged with other Google data. The IP addresses are anonymized so that an assignment is not possible (IP masking).

You can prevent the installation of cookies by setting your browser software accordingly; however, we would like to point out that in this case, you may not be able to use all the functions of this website to their full extent.

You can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) and the processing of this data by Google by downloading and installing a browser add-on (https://tools.google.com/dlpage/gaoptout?hl=de).

As an alternative to the browser add-on, especially for browsers on mobile devices, you can also prevent Google Analytics from collecting data by clicking on this link. An opt-out cookie will be set to prevent the future collection of your data when you visit this website. The opt-out cookie is only valid in this browser and only for our website and is stored on your device. If you delete the cookies in this browser, you will need to set the opt-out cookie again.

Further information on data protection in connection with Google Analytics can be found in the Google Analytics Help (https://support.google.com/analytics/answer/6004245?hl=de).

b) GOOGLE ADS

Our website uses Google Conversion Tracking. If you have reached our website via an ad placed by Google, Google Ads will set a cookie on your computer. The conversion tracking cookie is set when a user clicks on an ad placed by Google. If the user visits certain pages of our website and the cookie has not yet expired, we and Google can recognize that the user clicked on the ad and was redirected to this page. Each Google Ads customer receives a different cookie. Cookies cannot therefore be tracked through the websites of Ads customers. The information collected using the conversion cookie is used to generate conversion statistics for Ads customers who have opted for conversion tracking. Customers can find out the total number of users who clicked on their ad and were redirected to a page with a conversion tracking tag. However, they do not receive information that personally identifies users.

If you do not wish to participate in tracking, you can refuse the setting of a cookie required for this - for example, via browser settings that generally deactivate the automatic setting of cookies. You can also deactivate cookies for conversion tracking by setting your browser to block cookies from the domain "www.googleadservices.com". Google's data protection declaration on conversion tracking can be found here (https://services.google.com/sitestats/de.html).

c) GOOGLE RECAPTCHA

To protect your inquiries via the internet form, we use the reCAPTCHA service of Google Inc. (Google). The query is used to distinguish whether the input is made by a human being or abusively by automated, machine processing. The query includes sending the IP address and any other data required by Google for the reCAPTCHA service to Google. For this purpose, your input will be transmitted to Google and used there. However, your IP address will be shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area beforehand. Only in exceptional cases will the full IP address be 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 this service. The IP address transmitted by your browser as part of reCAPTCHA will not be merged with other data from Google. This data is subject to Google's data protection regulations. For more information about Google's privacy policy, please visit: https://policies.google.com/privacy?hl=de.

7. NEWSLETTER

If you have expressly consented in accordance with Art. 6 para. 1 sentence 1 lit. a GDPR, we will use your email address to regularly send you our newsletter.

Content: We send newsletters, emails, and other electronic notifications with promotional information (hereinafter referred to as "newsletter") only with the consent of the recipients or legal permission.

Double-Opt-In and Logging: Registration for our newsletter is done in a so-called double-opt-in procedure. This means that after registration, you will receive an email asking you to confirm your subscription to the newsletter. This confirmation is necessary to prevent anyone from registering with foreign email addresses. Newsletter registrations are logged to demonstrate compliance with legal requirements for the registration process. This includes storing the IP address as well as the date and time of registration and confirmation. Changes to your data stored by our email service provider are also logged.

Registration Data: To subscribe to the newsletter, it is sufficient to provide your email address. Optionally, we ask you to provide a name for personalization in the newsletter.

The sending of the newsletter and the associated measurement of success are based on the consent of the recipients in accordance with Art. 6 para. 1 lit. a, Art. 7 GDPR or, if consent is not required, on our legitimate interests in direct marketing pursuant to Art. 6 para. 1 lit. f. GDPR.

The logging of the registration process is based on our legitimate interests in accordance with Art. 6 para. 1 lit. f GDPR. Our interest is in using a user-friendly and secure newsletter system that serves both our business interests and user expectations and also allows us to prove consents.

Unsubscribe/Revocation: You can unsubscribe from receiving our newsletter at any time, i.e., withdraw your consent. A link to unsubscribe from the newsletter can be found at the end of each newsletter. To be able to prove a previously given consent, we store unsubscribed email addresses for up to three years based on our legitimate interests before deleting them. The processing of this data is limited to the purpose of potential defense against claims. An individual request for deletion is possible at any time, provided that the former existence of consent is confirmed simultaneously.

A) KLAVIYO

The newsletters are sent using the mailing service provider "Klaviyo," a newsletter delivery platform provided by the US company Klaviyo, Inc., 125 Summer Street, Boston, MA 02110, USA. You can view the privacy policy of the mailing service provider here: https://www.klaviyo.com/legal/privacy/privacy-notice. Klaviyo, Inc. is certified under the Privacy Shield agreement, providing a guarantee of compliance with European data protection standards (https://bbbprograms.org/programs/all-programs/bbb-eu-privacy-shield-consumers/ProcessForConsumers).

The mailing service provider is used based on our legitimate interests in accordance with Art. 6 para. 1 lit. f GDPR and an order processing contract in accordance with Art. 28 para. 3 sentence 1 GDPR.

The mailing service provider may use recipient data in pseudonymous form, i.e., without attribution to a user, for the optimization or improvement of its own services, such as technical optimization of sending and displaying newsletters or for statistical purposes. However, the mailing service provider does not use the data of our newsletter recipients to write to them directly or to pass on the data to third parties.

B) NEWSLETTER - MEASUREMENT OF SUCCESS

The newsletters contain a so-called "web beacon," i.e., a pixel-sized file that is retrieved from our server or, if we use a mailing service provider, from its server when the newsletter is opened. As part of this retrieval, technical information such as information about the browser and your system, as well as your IP address and the time of retrieval, is initially collected.

These pieces of information are used for technical improvement of the services based on technical data or audience behavior analysis, such as retrieval locations (identifiable by IP address) or access times. Statistical surveys also include determining whether newsletters are opened, when they are opened, and which links are clicked. Although these pieces of information can be attributed to individual newsletter recipients for technical reasons, it is neither our intention nor, if used, that of the mailing service provider to observe individual users. The evaluations instead help us to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.

A separate revocation of the measurement of success is unfortunately not possible; in this case, the entire newsletter subscription must be terminated.

8. SOCIAL MEDIA PLUGINS

We use social media plugins from the following social networks on our website.

A) FACEBOOK

On our website, we use social plugins ("plugins") from the social network facebook.com, which is operated by Facebook Inc., 1 Hacker Way, Menlo Park, California 94025, USA ("Facebook"). When you open our website with the plugin, it establishes a direct connection to Facebook's servers through your browser. This transfers information to Facebook that you have visited the page.

If you are logged into your Facebook account, clicking on the plugin may directly associate the visit to our website with your profile. Even if you do not have a profile, it cannot be ruled out that your IP address may be stored by Facebook.

For the purpose and scope of data collection and further processing and use of the data by Facebook, as well as your related rights and privacy settings, please refer to Facebook's privacy policy (https://www.facebook.com/about/privacy/).

If you are a Facebook member and do not want Facebook to collect data about you through our online offering and link it to your stored member data at Facebook, you must log out of Facebook before visiting our website and delete the corresponding Facebook cookies. It is also possible to block Facebook social plugins with browser add-ons, such as the "Facebook Blocker."

In addition to the browser add-on, especially for mobile devices, you can prevent tracking by Facebook on our pages. An opt-out cookie will be set that prevents the future collection of your data when visiting this website.

Web tracking for Facebook on this site is activated. Deactivate now.

The opt-out cookie applies only to this browser and only to our website and will be stored on your device. If you delete the cookies in this browser, you must set the opt-out cookie again.

B) INSTAGRAM

Our website may include plugins from the social network Instagram (Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA). You can recognize the Instagram plugin by the "Instagram button" on our website. If you click the Instagram button while logged into your Instagram account, you can link the content of our web pages to your Instagram profile. This allows Instagram to associate the visit to our pages with your user account.

Please note that as the provider of our website, we have no knowledge of the content of the transmitted data or its use by Instagram. For more information on Instagram's privacy policy, please visit https://instagram.com/about/legal/privacy/.

C) PINTEREST

Our website may include plugins from the social network Pinterest (Pinterest Inc., 808 Brannan Street San Francisco, CA 94103-490, USA). When you click the "Pin it" button, a connection is established to Pinterest's servers. The plugin transmits protocol data to Pinterest's server in the USA. This protocol data may include your IP address, the addresses of the websites visited, which also contain Pinterest functions, the type and settings of the browser, date and time of the request, your use of Pinterest, and cookies.

If you are logged into your Pinterest account, clicking the "Pin it" button may directly associate the visit to our website with your profile. Even if you do not have a profile, it cannot be ruled out that your IP address may be stored by Pinterest. This allows Pinterest to associate the visit to these pages with your user account. To prevent Pinterest from collecting data when visiting our website, you must log out of your Pinterest account before clicking the "Pin it" button.

For more information, including privacy settings, please refer to Pinterest's privacy policy: https://about.pinterest.com/de/privacy-policy.

9. INTEGRATION OF THIRD-PARTY SERVICES AND CONTENT

Within our online offering, we use third-party content or service offerings on the basis of our legitimate interests (i.e., interest in the analysis, optimization, and economic operation of our online offering within the meaning of Art. 6 para. 1 lit. f. GDPR) to incorporate their content and services, such as videos or fonts (hereinafter uniformly referred to as "content").

This always presupposes that the third-party providers of this content perceive the IP address of the users, since they could not send the content to their browser without the IP address. The IP address is therefore required for the display of this content. We make every effort to use only those contents whose respective providers use the IP address solely for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. The "pixel tags" can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user's device and may include technical information about the browser and operating system, referring web pages, visit time, and other information about the use of our online offering, as well as be linked to such information from other sources.

10. DATA SECURITY

We make every effort to store your personal data in such a way that it is not accessible to third parties or the public. If you wish to contact us by email, please note that the confidentiality of the information transmitted cannot be guaranteed completely via this communication method. Therefore, we recommend sending confidential information to us exclusively by postal mail.

11. UPDATES AND AMENDMENTS TO THIS PRIVACY POLICY

Applicable law and our business practices change from time to time. When we update our privacy policy, we will publish the changes on our website. If we significantly change the way we process your personal data, we will inform you in advance. If legally required, we will obtain your consent before implementing such changes. We strongly recommend that you read our privacy policy and stay informed about our practices. This privacy policy was last modified in May 2018.

12. NAME AND CONTACT INFORMATION OF THE DATA CONTROLLER

This privacy information applies to all content at www.cuffcph.com, including newsletters or contests for which you register.

DATA CONTROLLER: 

JHT Company GmbH 

Uhlandstraße 28 

10719, Berlin - DE 

Company No: HRB 236140 B 

VAT: DE348808758 

Attention: Data Protection Officer support@cuffcph.com