1. DATA CONTROLLER
The data controller is ZLS Services, which can be contacted as follows:
ZLS Services GmbH
Hamburger Allee 56
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.
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
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
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
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:
10. CHILD’S AND ADOLESCENT’S PRIVACY
12. CONTACT DETAILS:
ZLS Services GmbH
Hamburger Allee 56
Effective date: March 11, 2019