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Privacy Policy

This Privacy Policy describes and explains how ZLS Services GmbH (a company, duly organized under the laws of Germany whose registered office is at Hamburger Allee 56 60486 Frankfurt, Germany; HRB 50274) collects, uses and otherwise processes Personal data of our website users (also refers to as "you", "your"). When we refer to "ZLS Services", "we", "our" or "us" in this document, we mean the company ZLS Services GmbH, which acts as a controller of the personal data that is being collected from You.

We pay your attention, that the provisions of this Privacy Policy do not apply to third party’s online resources to which our website may link, where ZLS Services does not control the content or the privacy policy of such resources.

1. DATA CONTROLLER

The data controller is ZLS Services, which can be contacted as follows:

ZLS Services GmbH

Hamburger Allee 56

60486 Frankfurt

Germany

Tel.: +496926947062

Email: office@zls-services.de

If you have any questions about data protection, please feel free to contact us.

2. WHAT PERSONAL DATA WE MAY COLLECT AND HOW

WE COLLECT YOUR PERSONAL DATA

ZLS Services DOES NOT collect and never ask you to provide your sensitive personal data. We only process your personal data with your knowledge and to the extent that is actually needed to achieve the processing purposes outlined below. The personal data that ZLS Services may collect and further process, as well as the ways of collection includes:

1. The data you provide us directly when:

a) You sign up for an account on our website. When you create your personal customer account, we collect the following personal data: your first and last name, e-mail, phone number, fax, your address (including name of street, city, post code, country, region/state). If you decide to register your customer account by clicking on “Login/Register”, we will also process this data to register you as our Switchonshop customer in case you visit or make purchases from our online shop again in the future. Namely, you will not have to re-enter the information we need to perform the contract each time that you place an order with us and will allow you to see purchases that you have already made in your customer account at any time.

b) You contact with us by filling contact forms on our website. When you fill out contact forms on our websites, we collect the personal data that you enter in these forms, which includes your name and email address.

c) You contact with us via e-mail or by phone. In this case we may collect the following personal data: name, email address, phone number and any other information you choose to include in the title and in the text of your email, as well as the information you choose to inform us during the call.

d) You enter into a contract with us or otherwise request our services. We collect your name, email and postal address, telephone number, country of residence, MAC address and serial number of your device that you provide to us in the process of negotiation, execution or performance of contracts (e.g. supply or customer support), payment information, such as credit/debit card number, expiration date, security code and other related billing information.

e) You choose to specify your personal data in your comments to our blogs and/or your reviews to the products presented on our website.

2. Automatically collected data when you visit and surf our website. We may collect information about your device and how you use our website, including IP address; the type of device you are using; platform type; operating system version; mobile device’s identifiers; your browser type and language; URLs of website and webpage, that you visit; the number of clicks on the web page; the amount of time spent on web page; pages viewed on our website. We may use cookies and third-party services, that collect, monitor and analyse this type of information in order to increase the functionality of our website. When first time entering our website, we request your acceptance for using cookies and analytic services. To learn more about cookies learn our Cookie Policy.

3. THE LEGAL GROUNDS AND PURPOSES OF COLLECTING AND PROCESSING YOUR PERSONAL DATA

ZLS Services processes Your personal data based on several lawful grounds:

1. Performance of the contract we have with you. This also includes negotiation of a prospective contract. We use your first name, surname, address, contact and payment details to provide you goods and services under the contract; to send you your order invoice; to assign any order cancellations, complaints and other enquiries made after the order has been placed to you and to your order and to handle your requests and enquiries; communicate with you regarding the contract and otherwise exercise our rights and perform obligations related to the contract.

2. Our legitimate interests. We use personal data collected from you to realise and protect our legitimate interests, as follows:

- contact details, such as name, postal and email address, phone number, are required for: providing the services through our website; communication with You; direct marketing, unless You have objected to the use of your personal data for this purpose; fraud detection; protection against fraud, Internet scams; setting disputes with respect to the ordered products.

- information concerning the type of your mobile device, IP address of your computer or mobile device, type of operating system, operating system version is required for: identifying the inter-operability of our website with your mobile device or computer and system administration.

- data about links you click and other behavioral data with respect to your usage of our website is necessary for: improving the quality of our services; marketing, research and analytical purposes to make our website user-friendly; understanding the relevance of our website functionality and your need in respect of our services; to analyse your preferences and shopping habits, to analyze trends and statistics;

- information about identity, device, Mac address of product, location information is necessary to prevent fraud and abuse and to prevent security breaches.

In addition, ZLS Services may also use your personal data as follows:

• providing customer and/or operational support;

• analysing and managing informational, commercial and other risks; and

• exercising our commitments arising from our relations with you and relating to the usage of our website.

4. MAIN PROCESSING ACTIONS WITH YOUR PERSONAL DATA

ZLS Services may process your personal data mostly by way of collection, storing, recording and structuring. We have implemented and maintain appropriate technical and organisational measures in order to protect against the loss, misuse and alteration of the personal data, and also to prevent personal data from being accessed by unauthorised persons. All your personal data is stored on secure servers. We shall not sell your personally identifiable data to any third parties, including but not limited, for their own direct marketing use.

5. HOW WE SHARE INFORMATION WE COLLECT

In view of the provisions of current legislation, ZLS Services may share your personal data with the following third parties:

- our employees responsible for the maintenance of our website and customer relations;

- corresponding service providers where applicable in order to assist us with the goods or services that you have requested from us, as well as to meet our commitments arising from our relations with you and relating to the usage of our website. The services provided by those service providers may include: delivery of ordered goods, authorization and processing of your payments, marketing and promotional material distribution, web site evaluation. In this case such service providers are obliged to provide you with an adequate level of personal data protection;

- the persons designated by you as authorised to give instructions on your behalf;

- the relevant government regulators, public authorities, judicial bodies or law enforcement agencies to meet legal requirements, including complying with court orders, valid discovery requests etc. or to comply with any laws, rules, guidelines and regulations imposed by any governmental authority;

- the corresponding law enforcement agencies in order to investigate, eliminate and/or prevent offences;

- our successors and assigns on the basis of legitimate interests in the course of our normal business activities. We shall take all steps reasonably necessary to ensure that relevant appropriate safeguards were taken for treating your personal data securely. We will inform you of this in advance and ensure that your personal information is secure.

ZLS Services may also generally disclose your data in an anonymised format by taking all reasonable steps to ensure that such data does not contain your personally identifying information.

6. INTERNATIONAL DATA TRANSFERS

ZLS Services may transfer your personal data abroad for processing where required for any of the purposes and cases set out above (see clause 3 and 5 of this document). When doing so, we will comply with applicable data protection requirements and take appropriate safeguards to ensure the security and integrity of your personal data.

For users of this website who are based in the EU or European Economic Area (“EEA”), you should be aware that information which you provide to ZLS Services may be transferred to countries outside of the of the EU or EEA (including the United States) which do not always have the same standard of data protection as those inside the EU or EEA. For the purposes of processing your data, we will ensure a data protection level equivalent to the minimum level within the EU and EEA including entering into the EU Standard Contractual Clauses or by other similar protective measures.

Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the USA. For further details, see European Commission: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/eu-us-data-transfers_en

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7. YOUR RIGHTS WITH RESPECT TO YOUR PERSONAL DATA

a) Access to your personal data.

You have a right at any time to request confirmation as to whether or not your personal data are being processed, as well as clarifying the basis and purposes of processing. If your Personal data are being processed, you may request its copy in a machine-readable form.

b) Rectification of your personal data.

If you discover the incorrectness of your personal data as well as necessity of its amending necessary for receiving the services provided through our website, You may contact us immediately for making required rectification.

c) Erasure of your personal data.

You may exercise the right to request the erasure of Your personal data if:

- the personal data is no longer necessary for the purposes which ZLS Services originally collected or processed it for;

- your personal data were provided by third parties without Your knowledge and consent;

- there is no overriding legitimate interest to continue the processing of your personal data;

- your personal data is used only for direct marketing purposes, and you object to such processing;

- it is necessary to comply with a legal request or legal obligation.

d) Object to processing your personal data.

You may request to cease processing of your personal data if:

- there is no overriding legitimate interest to continue the processing of your personal data;

- your personal data is used only for direct marketing purposes and you object to such processing;

- it’s necessary to comply with a legal request or legal obligation.

e) Appeal to a corresponding supervisory authority.

If you consider that we permitted any negligence with respect to collecting or processing your personal data, You have a right to lodge a complaint to a corresponding supervisory authority. The supervisory authority responsible is:

Data Protection Officer of Hesse

Gustav-Stresemann-Ring 1

65189 Wiesbaden, Germany

Tel: +49 611/1408 0

Fax: +49 611/1408 900 or 901

f) Be aware of any correction or erasure of Your personal data, restriction of processing, and recipients of your personal data; and

g) Not to be subject to a decision based solely on automated processing. You have the right to be free

from decisions based solely on automated processing of your personal data, including profiling, that affect you. We also pay your attention that we will not use your personal data to make automated decisions that affect you.

h) Right to data portability.

You have a right to request us to transfer any personal data you have provided to us during our contractual relationship on such lawful ground as «Performance of the contract we have with you». We will provide the data in a structured and machine-readable format to you or any third party specified by you as the proper subject of data acquisition.

8. PERIOD OF PERSONAL DATA PROCESSING

We shall try to process your personal data as limited as possible. Processing of your personal data is carried out for the limited period until:

• the personal data is no longer necessary with respect to the purposes for which they were collected or otherwise processed;

• receiving your request concerning erasure of Your personal data, if applicable;

• we discover that minors provided their personal data without corresponding parental or guardian consent, or data relating to such minors is provided to us by third parties.

If we can use Your personal data as the evidence of fraud, or breach of provisions of the contract, we may process such personal data during the limitation period under applicable law.

9. ANALYTICS AND OTHER THIRD PARTY SERVICES

1) We use Google Analytics a web analysis service of Google, Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043 USA, to gather data on the number of people accessing our website, where they are accessing from, what pages they visit, and what technology they are using. Google Analytics does allow us to understand our users as a group, for example by recording what browsers are being used. Google Analytics employs cookies that are stored to your computer in order to facilitate an analysis of your use of the site as well as to identify you as a unique user the next time you visit our website. For the cases in which personal data is transferred to the US, Google inc. has self-certified pursuant to the EU-US Privacy Shield Framework and pursuant to Swiss-U.S. Privacy Shield Framework, which ensures compliance with the level of data protection in the EU and Switzerland. To learn more how Google Analytics collects data as well as to familiarize Yourself with the privacy policy of Google Analytics use the link https://www.google.com/analytics/terms/us.html . You can always opt out of being included in Google Analytics, following the link: https://tools.google.com/dlpage/gaoptout .

2) We use Yandex.Metrica web analytics service provided by Yandex Oy Limited Company - Moreenikatu 6, 04600 Mantsala, Finland. Yandex.Metrica uses “cookies,” small text files placed on users’ device to analyze user activity. Information collected by cookies does not reveal your identity, but it can help us to improve our website performance. The information collected (your IP address, the time you visit our Website, the type of browser you use, the web-pages you consult) is transferred to and stored by Yandex in the European Economic Area and Russian Federation. Russian Federation is a jurisdiction outside the European Economic Area, which has not been recognized by the European Commission as providing an adequate level of personal data protection. Therefore, Yandex has taken appropriate measures to ensure Personal information is handled according to applicable EU data protection rules. More information about Yandex Privacy policy can be found here: https://yandex.ru/legal/confidential/?lang=en. You can stop using cookies be making relevant adjustments in browser settings. You can also use the tool https://yandex.com/support/metrika/general/opt-out.html. However, it can affect some website functions. By using our website, you agree that Yandex can process your data in the above manner and for the above purposes. 

3) Social plugins. You will see the social plugins on certain webpages of our website. These plugins are presented as buttons on our website and are identifiable by the logo of the corresponding social media services. The social plugins enable an automated communication (data exchange) between the corresponding web page of our website and the social media services in accordance with their corresponding privacy policies. When you visit our website these buttons are deactivated. After their activation by clicking on them, a direct link to the server of the respective social network is established. By clicking on one of these buttons you agree to the use of this plugin and therefore the transfer of personal data to the respective social media service. The contents of the button are then transmitted from the social network directly to your browser and incorporated in the website by it. After activation of a button, the social network can retrieve data, independently of whether you interact with the button or not. If you are logged on to a social network, the network can assign your visit to the website to your user account. If you are a user of a social network and do not wish it to combine data retrieved from your visit to our website with your user data, you must log out from the social network concerned before activating the buttons. We have no influence on the scope of data that is collected by the social networks through their buttons.

We would like to give you some information about the social plugins we use on our website. We use the following social plugins ('buttons') of social networks:

a) Facebook - a service operated by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA. Facebook inc. has self-certified pursuant to the EU-US Privacy Shield Framework and pursuant to Swiss-U.S. Privacy Shield Framework, which ensures compliance with the level of data protection in the EU and Switzerland. Please note that we have no knowledge as to the contents of the submitted data or its use by Facebook. For more details about how Facebook Inc. collects and uses the personal data learn please Facebook privacy policy following the link https://www.facebook.com/about/privacy/ .

b) Twitter – a service operated by Twitter Inc. 795 Folsom St., Suite 600, San Francisco, CA 94107, USA. Through the use of Twitter and the “Re-Tweet” the web pages you visit are linked to your Twitter account and made ​​known to other users. This data shall be transmitted to Twitter. Twitter inc. has self-certified pursuant to the EU-US Privacy Shield Framework and pursuant to Swiss-U.S. Privacy Shield Framework, which ensures compliance with the level of data protection in the EU and Switzerland. For more details about how Twitter Inc. collects and uses the personal data learn please Twitter privacy policy following the link https://twitter.com/privacy

c) Linkedin – a service provided by LinkedIn Corporation 2029 Stierlin Court, Mountain View, CA 94043, USA. LinkedIn Corporation has self-certified pursuant to the EU-US Privacy Shield Framework and pursuant to Swiss-U.S. Privacy Shield Framework, which ensures compliance with the level of data protection in the EU and Switzerland. For more details about how LinkedIn Corporation collects and uses the personal data learn please LinkedIn Corporation privacy policy following the link https://www.linkedin.com/legal/privacy-policy

10. CHILD’S AND ADOLESCENT’S PRIVACY

The protection of personal data of children and adolescents is of particular concern to ZLS Services. If You are a minor under the legislation of Your residence, You have to receive a permission from Your parents or guardians to provide us Your personal and other data according to this Privacy Policy, as well as applying the provisions of this Privacy Policy to You. In any case we do not knowingly collect, use and otherwise process personal and other data from minors and thereby shall not be liable for collection and further processing of the above-mentioned information. We will delete immediately such data in case of discovering that fact.

11. UPDATES OF PRIVACY POLICY

We reserve a right to update the text of this Privacy Policy by making alterations of its provisions and/or amending them by new provisions and or deleting the existing provisions, and/or changing them in any other way at any time. The effective date of its current version You may find at the end of the document. We shall notice You by e-mail about the entry into force of the new version of this Privacy Policy, if you have a personal customer account, or by means of providing a corresponding notice on this website prior to the amendments becoming effective. We recommend you to review this page occasionally for receiving the latest data with respect to the provisions of this document.

12. CONTACT DETAILS:

If you have any questions or complaints regarding this Privacy Policy or you want to exercise Your data protection related rights, you can communicate with us at the email address office@zls-services.de or by post at the addresses below:

ZLS Services GmbH

Hamburger Allee 56

60486 Frankfurt

Germany

Effective date: March 11, 2019

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