Privacy Policy

The person responsible for data processing is:
Cornelius Huber
Poststr. 38
75210 Keltern
Deutschland

hello@circulawatches.com

Thank you for your interest in our online shop. Protection of your privacy is very important to us. Below you will find extensive information about how we handle your data.

1. Access data and hosting

You may visit our website without revealing any personal information. With every visit on the website, the web server stores automatically only a so-called server log file which contains e.g. the name of the requested file, your IP address, the date and time of the request, the volume of data transferred and the requesting provider (access data), and documents the request.

These access data are analysed exclusively for the purpose of ensuring the smooth operation of the website and improving our offer. This serves according to art. 6 (1) 1 lit f GDPR the protection of our legitimate interests in the proper presentation of our offer that are overriding in the process of balancing of interests. All access data are deleted no later than seven days after the end of your visit on our website.

Third-party hosting services
Data are also processed by a third-party provider that we have engaged to render hosting and website presentation services on our behalf. This provider processes on its servers all data that are collected in the manner specified below when you visit our website or fill in forms made available for this purpose in our online shop. Data are processed on other servers only in the scope described herein.

This service provider is based in an EU or EEA member state.

2. Data collection and use for processing the contract and for opening a customer account

We collect personal data that you voluntarily submit to us when you place an order, contact us (e.g. via contact form or by email) or open a customer account with us. Mandatory fields are marked as such because we absolutely need those data to perform the contract or process your contact request or open your customer account, and you would otherwise not be able to complete your order and/or create your customer account or send the contact request. It is evident in each input form what data are collected. We use the data that you disclose to us to perform the contract and process your enquiries according to art. 6 (1) 1 lit b GDPR. Upon completion of the contract or deletion of your customer account, any further processing of your data will be restricted, and your data will be deleted upon expiry of the retention period applicable under relevant regulations, unless you expressly consent to the further use of your data or we reserve the right to further use your personal data in the scope and manner permitted by law, of which we inform you in this notice. Your customer account can be deleted at any time. For this purpose you can either send a message to the contact option specified below or use the relevant function available in the customer account.

3. Transfer of data

We disclose your data to the shipping company in the scope required for the delivery of the ordered goods according to art. 6 (1) 1 lit. b GDPR. Depending on the payment service provider you have selected during the ordering process, we disclose the payment details collected for order processing purposes to the bank commissioned to handle the payment and, as the case may be, to the payment service provider commissioned by us or to the selected payment service. Some of those data are collected by the selected payment service providers themselves if you open an account with them. In such a case, during the ordering process, you must register with your payment service provider using your access data. In this respect, the privacy notice of the relevant payment service provider applies.

We are using payment service providers based outside the EU or EEA. We disclose your personal data to this company only in the scope required for the contract fulfilment.

We also use an external inventory control system to process orders and contracts. The data transfer or processing that takes place in this respect is based on order processing.

We use a shipping service provider that is based in a country outside the EU. We disclose your personal data to this company only in the scope required for the contract fulfilment.

4. Email newsletter

E-mail advertising if you subscribe to the newsletter
If you subscribe to our newsletter, we will regularly send you our e-mail newsletter based on your consent according to art. 6 (1) 1 lit a GDPR, using the data required or disclosed by you separately for this purpose.

You may unsubscribe from the newsletter service at any time. For this purpose you can either send a message to the contact option specified below or use the opt-out link in the newsletter. Upon unsubscription, we will delete your email address unless you have expressly consented to the further use of your data or we reserve the right to further use your personal data in the scope and manner permitted by the law, of which we inform you in this notice.

E-mail advertising if you do not subscribe to the newsletter and your right to opt out
If we receive your e-mail address in connection with the sale of a product or service and you have not opted out and you are not a consumer who has his habitual residence in Poland, we reserve the right to regularly email you offers for products from our product range that are similar to those you have already purchased. This serves the protection of our legitimate interests in promoting and advertising our products to customers that are overriding in the process of balancing of interests.
You can opt out of this use of your email address at any time by sending a message to the contact option specified below or by using the opt-out link in the advertising email, without incurring any costs beyond the cost of transfer calculated at the base rates.

The newsletter is sent to you by our service provider who processes data on our behalf and to whom we disclose your email address.

This service provider is based in the USA and is certified to the EU-US Privacy Shield. The current certificate can be looked up here. Based on this agreement between the USA and the European Commission, the latter has recognised entities certified to the Privacy Shield as those ensuring an adequate level of data protection.

Postal advertising and your right to object
In addition, we reserve the right to use your first and last name and your postal address for our own advertising purposes, e.g. for sending interesting offers and information about our products by post. This serves to safeguard our legitimate interests, which predominate in the context of a weighing of interests, in addressing our customers with advertising in accordance with Art. 6 Para. 1 S. 1 lit. f GDPR.

5. Use of data in payment processing
Identity and credit checks when choosing Klarna payment services
If you choose Klarna’s payment services, we ask for your consent that we may transmit the data necessary for the processing of the payment and an identity and credit check to Klarna. In Germany, the credit bureaus mentioned in Klarna’s data protection declaration can be used for identity and credit checks.
Klarna uses the information received about the statistical probability of a payment default for a balanced decision on the establishment, implementation or termination of the contractual relationship.
You can revoke your consent at any time by sending a message to the contact details below. As a result, we may no longer be able to offer you certain payment options. You can withdraw your consent to this use of personal data by Klarna at any time.

6. Integration of the Trusted Shops Trustbadge

The Trusted Shops Trustbadge is integrated on this website to display our Trusted Shops Trustmark and the collected reviews as well as to offer Trusted Shops products to buyers after an order.

This is necessary to safeguard our legitimate prevailing interests in an optimal marketing by ensuring the safety of your purchase according to Article 6 (1) f GDPR. The Trustbadge and the services advertised with it are an offer of the Trusted Shops GmbH, Subbelrather Str. 15C, 50823 Cologne, _Germany. The Trustbadge is made available by a CDN provider (Content-Delivery-Network) as part of order processing. The Trusted Shops GmbH uses also service provider from the USA. An adequate level of data protection is guaranteed. Further information to the data security of the Trusted Shops GmbH can be found here: https://www.trustedshops.co.uk/imprint/

When the Trustbadge is called up, the web server automatically saves a server log file which contains, for example, your IP address, the date and time of the call, the amount of data transferred and the requesting provider (access data) and documents the call. Individual access data are stored in a security database for the analysis of security problems. The log files are automatically deleted 90 days after creation at the latest.

Further personal data will be transferred to Trusted Shops GmbH if you decide to use Trusted Shops products after completing an order or have already registered for use. The contractual agreement made between you and Trusted Shops applies. For this purpose personal data is automatically collected from the order data. Whether or not you are already registered as a Trusted Shops customer is automatically checked by means of a neutral parameter, the e-mail address hashed by cryptological one-way function. The e-mail address is converted to this hash value, which cannot be decrypted by Trusted Shops before it is transmitted. After checking for a match, the parameter is deleted automatically.

This is necessary for the fulfillment of our and Trusted Shops’ legitimate prevailing interests in the provision of the buyer protection linked to the specific order and the transactional review services in accordance with Art. 6 para. 1 s. 1 lit. f GDPR. Further details, including your right to object, can be found in the Trusted Shops Privacy Policy linked above and within the Trustbadge.

7. Cookies and web-analysis

In order to make visiting our website attractive and to enable the use of certain functions, to display suitable products or for market research, we use so-called cookies on various pages, provided that you have given your consent to this in accordance with Art. 6 Para. 1 S. 1 lit. a GDPR.

To improve the user experience on our website and enable you to use its certain features in order to show suitable products or conduct market research, some pages of this website use the so-called cookies. This serves the protection of our legitimate interests in the optimised presentation of our offer according to art. 6 (1) 1 lit a GDPR that are overriding in the process of balancing of interests. A cookie is a small text file which is stored automatically on your end device. Some of the cookies we use are deleted after you close the browser session, i.e. when you close the browser (that’s the so-called session cookies). Other cookies are stored in your end-user device and enable us to recognise your browser when you visit us again (persistent cookies). To check the cookie storage period, you can use the Overview function in the cookie settings of your web browser. You can configure your browser for it to inform you whenever a page uses cookies and decide on a case-by-case basis whether to accept or reject the cookies on a given website or generally. Every browser has a different policy for managing the cookie settings. The browser’s policy is described in the Help menu of every browser and explains how you can change your cookie settings. To find out how to change the settings in your browser, see the links below:
Microsoft Edge™: https://support.microsoft.com/en-us/help/4468242/microsoft-edge-browsing-data-and-privacy
Safari™: https://support.apple.com/en-gb/guide/safari/sfri11471/mac
Chrome™: https://support.google.com/chrome/answer/95647?hl=en&hlrm=en
Firefox™: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
Opera™ : https://help.opera.com/en/latest/web-preferences/#cookies

Please note that disabling cookies may limit your access to some features of our website.

Borlabs Consent Management
We use Borlabs Consent Management (“Borlabs”) on our website to inform you about the technologies we use on our website and to obtain, manage and document your consent to the processing of your personal data using these technologies. This is necessary according to Art. 6 Para. 1 S. 1 lit. c GDPR to fulfill our legal obligation according to Art. 7 para. 1 GDPR to be able to prove your consent to the processing of your personal data, to which we are subject. The Borlabs consent management service is an offer from Borlabs – Benjamin A. Bornschein, Rübenkamp 32, 22305 Hamburg, which processes your data on our behalf. When you visit our website, the Borlabs web server saves a so-called server log file, which also contains your anonymised IP address, the date and time of your visit, device and browser information and information on your consent behavior. Your data will be deleted after three years, unless you have expressly requested further use of your data in accordance with Art. 6 Para. 1 S. 1 lit. a GDPR or we reserve the right to use data beyond this that is permitted by law and about which we will inform you in this declaration.

Using of Google (Universal) Analytics for web analytics
If you have given your consent to this in accordance with Art. 6 Para. 1 S. 1 lit. a GDPR, this website uses Google (Universal) Analytics for website analysis. The web analysis service is offered by Google Ireland Limited, a company incorporated and operated under Irish law with its registered office at Gordon House, Barrow Street, Dublin 4, Ireland. (www.google.de). For the purpose of website analytics, this website uses Google (Universal) Analytics, a web analytics service provided by Google LLC (www.google.com). This serves the protection of our legitimate interests in the optimised presentation of our offer according to art. 6 (1) 1 lit f GDPR that are overriding in the process of balancing of interests. Google (Universal) Analytics uses methods, like e.g. cookies, that enable an analysis of your use of the website. The information collected automatically by cookies about your use of this website are as a rule transmitted to and stored on a Google server in the United States. At the same time, as IP anonymisation is enabled on this website, the IP address will be shortened before being transmitted within the area of member states of the European Union or other parties to the Agreement on the European Economic Area. Only in exceptional cases, the full IP address will be sent to a Google server in the USA and shortened there. Generally, Google does not associate the anonymised IP address, transmitted from your browser through Google Analytics, with any other data held by Google.

As far as information is transmitted to and stored by Google on servers in the USA, the American company Google LLC is certified under the EU-US Privacy Shield. A current certificate can be viewed here. Based on this agreement between the USA and the European Commission, the latter has recognised entities certified to the Privacy Shield as those ensuring an adequate level of data protection.

You can revoke your consent at any time with future effect by downloading and installing the browser plug-in available under the following link: https://tools.google.com/dlpage/gaoptout?hl=en. This prevents the collection of the 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.

Alternatively to the browser plugin, you may click this link, to prevent Google Analytics from recording your data on this website in the future. In this process, an opt-out cookie will be stored on your end-user device. If you clear your cookies, you will have to click the link again.

8. Online-Marketing

Google Ads remarketing
We use Google AdWords to advertise our website in Google search results and on third-party websites. For this purpose, when you visit our website, the so-called remarketing cookie of Google is set on your browser, which allows the automatic displaying of interest-based advertising using a pseudonymous cookie ID and information about your website visits. This serves the protection of our legitimate interests in the optimal marketing of our website according to art. 6 (1) 1 lit f GDPR that are overriding in the process of balancing of interests.

Any data processing that goes beyond that scope takes place only if you have allowed Google to associate your web and app browsing history with your Google account and to use information from your Google account to personalise ads that you see across the web. If, in such a case, you visit our website while being signed in to Google, Google will use your data together with Google Analytics data to build and define audience lists for cross-device remarketing. For this purpose, Google will temporarily join your data with Google Analytics data to build audiences.

Google Ads is an offer from Google Ireland Limited, a company incorporated and operated under Irish law with its registered office at Gordon House, Barrow Street, Dublin 4, Ireland (www.google.de). As far as information is transmitted to and stored by Google on servers in the USA, the American company Google LLC is certified under the EU-US Privacy Shield. You will see the up-to-date certificate here. Based on this agreement between the USA and the European Commission, the latter has recognised entities certified to the Privacy Shield as those ensuring an adequate level of data protection.

You can disable the remarketing cookie via this link. In addition, you can obtain information about the setting of cookies from the Digital Advertising Alliance and accordingly adapt the settings of your browser.

Facebook-Pixel, Custom Audiences and Facebook-Conversion

We use Facebook to advertise our website. For this purpose, when you visit our website, the so-called “Facebook Pixel” of Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA, or if you are based in the EU, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”) is set on your browser. By doing so, users’ behavior can be tracked after they have seen or clicked on a Facebook ad. This technique is designed to evaluate the impact of Facebook ads for statistical and market research purposes and may help to optimize future advertising activities.

Facebook Inc. is headquartered in the USA und and is certified to the EU-US-Privacy Shield. You will see the up-to-date certificate here.

With the help of the Facebook pixel, Facebook is on the one hand able to determine the visitors of our online offer as a target group for the presentation of advertisements (so-called “Facebook ads”). Accordingly, we use the Facebook pixel to only display the Facebook ads placed by us to Facebook users who have also shown an interest in our online offer or who have certain characteristics (e.g. interests in certain topics or products based on the visited Websites) that we transmit to Facebook (so-called “Custom Audiences”). With the help of the Facebook pixel, we would also like to ensure that our Facebook ads correspond to the potential interest of the users and are not annoying. With the help of the Facebook pixel, we can also understand the effectiveness of the Facebook ads for statistical and market research purposes by seeing whether users have been redirected to our website after clicking on a Facebook ad (so-called “conversion”).

The processing of the data by Facebook takes place within the framework of Facebook’s data usage guidelines. Accordingly, general information on the presentation of Facebook ads can be found in Facebook’s data usage guidelines: https://www.facebook.com/policy.php. Special information and details about the Facebook pixel and how it works can be found in the Facebook help section: https://www.facebook.com/business/help/651294705016616.

You can object to the collection by the Facebook pixel and the use of your data to display Facebook ads. To set which types of advertisements are shown to you within Facebook, you can call up the page set up by Facebook and follow the instructions there on the settings for usage-based advertising: https://www.facebook.com/settings?tab=ads. The settings are platform-independent, i.e. they are adopted for all devices such as desktop computers or mobile devices.

Awin affiliate program

Our website participates in the Awin partner program. This is offered by AWIN AG, Eichhornstrasse 3, 10785 Berlin (hereinafter “Awin”). This is a so-called affiliate system in which persons registered with Awin (also “publishers”) advertise the products and services of the so-called “advertisers” on their websites using advertising material. This serves to safeguard our predominantly legitimate interests in optimizing and commercializing our online offer in accordance with Art. 6 Para. 1 lit. f) GDPR. Awin can use cookies to track the process of the respective order and, in particular, understand that you clicked on the respective link and then ordered the product via the Awin partner program.

You can prevent the setting of cookies by our contractual partners or our website at any time by setting your internet browser accordingly. In addition, cookies that have already been set can be deleted at any time via the Internet browser or other software programs.

You can find more information on data processing at Awin here.

9. Social media

Our online presence on Facebook, Youtube, Instagram, Pinterest, LinkedIn

Our presence on social networks and platforms serves for better, active communication with our customers and interested parties. There we provide information about our products and current special promotions.

When you visit our online presence on social media, your data can be automatically collected and saved for market research and advertising purposes. Using pseudonyms, so-called usage profiles are created from this data. These can be used to e.g. place advertisements inside and outside the platforms that presumably correspond to your interests. For this purpose, cookies are usually used on your device. The visitor behavior and the interests of the user are stored in these cookies. According to Art. 6 para. 1 lit. f. GDPR this serves to safeguard our legitimate interests, which predominate in the context of a weighing of interests, in an optimized presentation of our offer and effective communication with customers and interested parties. If you are asked for your consent to the data processing by the respective social media platform operator, e.g. with the help of a checkbox, the legal basis for data processing is Art. 6 Para. 1 lit. a GDPR.

As far as the aforementioned social media platforms are headquartered in the USA, the following applies: For the USA, the European Commission has issued an adequacy decision. This goes back to the EU-US Privacy Shield. A current certificate for the respective company can be viewed here.

For detailed information on the processing and use of the data by the providers on their pages, as well as a contact option and your related rights and setting options to protect your privacy, in particular options for objection (opt-out), please refer to the privacy policy of the provider linked below. If you still need help in this regard, you can contact us.

Facebook: https://www.facebook.com/about/privacy/
Data processing takes place on the basis of an agreement between jointly responsible parties in accordance with Art. 26 GDPR, which you can view here.
You can find further information on data processing when visiting a Facebook fan page (information on Insights data) here.

Google/ YouTube: https://policies.google.com/privacy?hl=en
Instagram: https://help.instagram.com/519522125107875
Pinterest: https://about.pinterest.com/de/privacy-policy
LinkedIn: https://www.linkedin.com/legal/privacy-policy
Options for objection (Opt-Out):
Facebook: https://www.facebook.com/settings?tab=ads
Google/ YouTube: https://adssettings.google.com/authenticated?hl=en
Instagram: https://help.instagram.com/519522125107875
Pinterest: https://www.pinterest.de/settings

10. Sending rating reminders by email

Rating reminder by Trusted Shops

If, when or after placing your order, you have given us your express consent to doing so according to art. 6 (1) 1 lit a GDPR, we will send your e-mail address to Trusted Shops GmbH, Subbelrather Str.15c, 50823 Cologne (www.trustedshops.de) so that they can send you an e-mail reminder for a rating.

This consent can be revoked at any time by sending a message to the contact option described below or directly to Trusted Shops.

11. Contact possibilities and your rights

You are entitled to be obtain free-of-charge information concerning data stored about your person and, as the case may be, to correct, restrict the processing, enable the portability of, or delete those data.

If you have any questions about how we collect, process or use your personal data, want to enquire about, correct, block or delete your data, or withdraw any consents you have given, or opt-out of any particular data use, please contact us directly using the contact data provided in our site imprint.

You may also submit a complaint to the responsible data protection supervisory authority.

Right to object
If we process personal data as described above to protect our legitimate interests that are overriding in the process of balancing of interests, you may object to such data processing with future effect. If your data are processed for direct marketing purposes, you may exercise this right at any time as described above. If your data are processed for other purposes, you have the right to object only on grounds relating to your particular situation.

After you have exercised your right to object, we will no longer process your personal data for such purposes unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.

This does not apply to the processing of personal data for direct marketing purposes. In such a case we will no longer process your personal data for such purposes.