PRIVACY NOTICE Vapomins Vertriebsgesellschaft mbH

Data privacy is of high importance for VAPOMINS and we want to be open and transparent with our processing of your personal data.

We therefore have a policy setting out how your personal data will be processed and protected. Please find here our updated version according to the General Data Protection Regulation (GDPR).

Who is the controller of your personal data?
The German Company, Vapomins Vertriebsgesellschaft mbH (“VAPOMINS”), is the controller of the personal data you submit to us and responsible for your personal data under applicable data protection law.

Vapomins Vertriebsgesellschaft mbH

Gollierstr. 70

80339 Munich

Germany

Companies register: Munich Central Register
Company registration number: HRB 21 49 34
Authorised representative: Johannes Schmid
VAT registration number: VAT NO. DE297265489

Where do we store your data?
The data that we collect from you is stored within the European Economic Area (“EEA”) but may also be transferred to and processed in a country outside of the EEA. Any such transfer of your personal data will be carried out in compliance with applicable laws.

For transfers outside the EEA, VAPOMINS will use Standard Contractual Clauses and Shields as safeguards for countries without adequacy decisions from the European Commission.

Who can access your data?
Your data may be shared within the VAPOMINS Company. We never pass on, sell or swap your data for marketing purposes to third parties outside the VAPOMINS group.

Data that is forwarded to third parties, is only used to provide you with our services. You will find categories of third parties under every specific process below. What is the legal ground for processing?
For every specific process of personal data we collect from you, we will inform you whether the provision of personal data is statutory or required to enter a contract and whether it is an obligation to provide the personal data and possible consequences if you choose not to.

What are your rights?
Right to access:
You have the right to request information about the personal data we hold on you at any time. You can contact VAPOMINS and we will provide you with your personal data via e-mail.

Right to portability:
Whenever VAPOMINS processes your personal data, by automated means based on your consent or based on an agreement, you have the right to get a copy of your data transferred to you or to another party. This only includes the personal data you have submitted to us.

Right to rectification:
You have the right to request rectification of your personal data if the information is incorrect, including the right to have incomplete personal data completed.

If you have a VAPOMINS account or Ambassdor Club membership you can edit your personal data under your account and membership pages.

Right to erasure:
You have the right to erase any personal data processed by VAPOMINS at any time except for the following situations:

*you have an ongoing matter with Customer Service
*you have an open order which has not yet been shipped or partially shipped
*you have an unsettled debt with VAPOMINS, regardless of the payment method
*if you are suspected or have misused our services within the last four years
*your debt has been sold to a third party within the last three years or one year for deceased customers
*your credit application has been rejected within the last three months
*if you have made any purchase, we will keep your personal data in connection to your transaction for book-keeping purposes

Your right to object to processing based on legitimate interest: 
You have the right to object to processing of your personal data that is based on VAPOMINS’s legitimate interest. VAPOMINS will not continue to process the personal data unless we can demostrate legitimate grounds for the process which overrides your interest and rights or due to legal claims.

Your right to object to direct marketing:
You have the right to object to direct marketing, including profiling analysis made for direct marketing purposes.

You can opt out from direct marketing by the following means:

* following the instruction in each marketing emails
* by editing the settings of your VAPOMINS account

Right to restriction:
You have the right to request that VAPOMINS restricts the process of your personal data under the following circumstances:

* if you  object to a processing based VAPOMINS:s legitimate interest, VAPOMINS shall restrict all processing of such data pending the verification of the legitimate interest.
* if you have claim that your personal data is incorrect, VAPOMINS must restrict all processing of such data pending the verification of the accuracy of the personal data.
* if the processing is unlawful you can oppose the erasure of personal data and instead request the restriction of the use of your personal data instead
* if VAPOMINS no longer needs the personal data but it is required by you to defend legal claims.

How can you exercise your rights?
We take data protection very seriously and therefore we have dedicated customer service personnel to handle your requests in relation to your rights stated above. You can always reach them at [email protected]

Right to complain with a supervisory authority:
If you consider VAPOMINS to process your personal data in an incorrect way you can contact us. You also have the right to raise a complaint to a supervisory authority.

Updates to our Privacy Notice:
We may need to update our Privacy Notice. The latest version of the Privacy Notice is always available on our website. We will communicate any material changes to the Privacy Notice, for example the purpose of why we use your personal data, the identity of the Controller or your rights.

Data for online purchases

Why do we use your personal data?
We will use your personal data to manage your purchase online at ainoha.com by processing your orders and returns via our online services and send you notifications of delivery status or in the event of any problems with the delivery of your items.

We will use your personal data to manage your payments.

We will also use your data in order to handle complaints and warranty matters for products.

Your personal data is being used to identify you and to  validate your legal age for shopping online and to confirm your address with external partners.

We want to offer you different payment alternatives and will carry out analysis in order to find out what payment alternatives are available to you, including your payment history and credit checks.

What types of personal data do we process?
We will process following categories of personal data

* contact information such as name, address, e-mail address and telephone number
* payment information and payment history
* credit information
* order information

If you have a AINOHA account or are a AINOHA Ambassador member we will also process your personal data submitted in relation to the account or membership such as

* account or membership ID
* shopping history

For the Share AINOHA Program, we work together with

Refersion Inc.

460 Broadway

New York, New York 10036, . In order to process your vouchers, we submit your personal data to refersion.com. Please find the privacy policy of refersion here: https://www.refersion.com/privacy

By signing up to our Share AINOHA Program, you accept their privacy policy and that you allow your data to be submitted.

Who has access to your personal data?
Your personal data that is forwarded to third parties, is only used to provide you with the services mentioned above, companies to validate your address, communication agencies to send you order confirmation, warehouse and distribution suppliers in connection with the delivery of your order. Payment service providers for your payment. Credit reference agencies for identity and credit checks and debt collection agencies.

Please be aware that many of these recipient companies have an independent right or obligation to process your personal data.

What is the legal ground to process your personal data?
The processing of your personal data is necessary for VAPOMINS to fulfil the service of managing and delivering the order to you.

How long do we save your data?
We will keep your data as long as you are an active customer.

Automated decision making:
When you apply for credit as a method of payment we will perform an automated decision-making process regarding your credit application. You have the right to to express your point of view and to contest the decision with a member of staff.

 

Usage of Cookies

A cookie is a small text file that is saved to, and, during subsequent visits, retrieved from your computer or mobile device. If you use our services, we will assume that you agree to the use of such cookie.

How do we use cookies?
We use permanent cookies to store your choice of start page and to store your details if you select “Remember me” when you log in.

We will use cookies to save your favourite products.

We use session cookies for example when you use the product filtration function, to check whether you are logged in or if you put an item in your shopping bag.

We use both first- and third-party cookies to collect statistics and user data in aggregate and individual form in analysis tools to optimize our site and to present you with relevant marketing material.

Some third-party cookies are set by services that appear on our pages and are not in our control. They are set by social media providers such as Twitter, Facebook and Vimeo and relate to the ability of users to share content on this site, as indicated by their respective icon.

We also use third-party cookies which performs cross-site tracking in order for us to give you marketing in other sites/channels.

What types of personal data do we process?
We will only connect your cookie ID to your personal data submitted and gathered in relation to your account or Club membership, if you are logged in to your account or the VAPOMINS Club.

Who has access to your personal data?
Data that is forwarded to third parties is only used to provide you with the services mentioned above, analysis tool in order to collect statistics to optimize our site and present you with relevant material.

What is the legal ground to process your personal data?
We will only connect your cookies to your personal data if you are logged in to your VAPOMINS account.

If you are logged in to your account the legal ground is based on our legitimate interest.

How long do we save your data?
VAPOMINS does not save your personal data. You can easily erase cookies from your computer or mobile device using your browser. For instructions on how to handle and delete cookies please look under “Help” in your browser. You can choose to disable cookies, or to receive a notification each time a new cookie is sent to your computer or mobile device. Please note that if you choose to disable cookies, you will not be able to take advantage of all our features.

 

CUSTOMER SERVICE

 

Why do we use your personal data?
We will use your personal data to manage your queries, to handle complaints and warranty matters for products and technical  support matters through e-mail, our chat function, telephone and through social media.

We may also contact you if there is a problem with your order.

What types of personal data do we process?
We will process any data you provide to us, including the following categories

* contact information such as name, address, e-mail address and telephone number
* birth date
* payment information and payment history
* credit information
* order information
* account or member number
* all correspondance in the matter

Who has access to your personal data?
Data that is forwarded to third parties, is only used to provide you with the services mentioned above. If you are a customer within the Asian region your data will be transfered to our external customer service agency.

What is the legal ground to process your personal data?
The processing of your personal data is based on VAPOMINS:s legitimate interest.

How long do we keep your data?
We will keep your data for 100 days for telephone and  e-mails logs and correncepondation and for 12 months for  case management.

Your right to object to processing based on legitimate interest:
You have the right to object to the processing of your personal data that is based on VAPOMINS’s legitimite interest. VAPOMINS will not continue to process the personal data unless we can demostrate a legitimate ground for the process which overrides your interest and rights or due to legal claims.

Please contact us in case of any questions.

Our privacy policy officer:
E-Mail: [email protected]
Phone: +4989 215406870

This privacy policy has been compiled to better serve those who are concerned with how their ‘Personally identifiable information’ (PII) is being used online. PII, as used in US privacy law and information security, is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. Please read our privacy policy carefully to get a clear understanding of how we collect, use, protect or otherwise handle your Personally Identifiable Information in accordance with our website.

What personal information do we collect from the people that visit our blog, website or app?

When ordering or registering on our site, as appropriate, you may be asked to enter your name, email address, mailing address, phone number, credit card information or other details to help you with your experience.

When do we collect information?

We collect information from you when you register on our site, place an order or enter information on our site.

How do we use your information?

We may use the information we collect from you when you register, make a purchase, sign up for our newsletter, respond to a survey or marketing communication, surf the website, or use certain other site features in the following ways:

  • To personalize user’s experience and to allow us to deliver the type of content and product offerings in which you are most interested.
  • To allow us to better service you in responding to your customer service requests.
  • To quickly process your transactions.

How do we protect visitor information?

Our website is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our site as safe as possible.

We use regular Malware Scanning.

Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. In addition, all sensitive/credit information you supply is encrypted via Secure Socket Layer (SSL) technology.

We implement a variety of security measures when a user places an order enters, submits, or accesses their information to maintain the safety of your personal information.

All transactions are processed through a gateway provider and are not stored or processed on our servers.

Do we use ‘cookies’?

Yes. Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your Web browser (if you allow) that enables the site’s or service provider’s systems to recognize your browser and capture and remember certain information. For instance, we use cookies to help us remember and process the items in your shopping cart. They are also used to help us understand your preferences based on previous or current site activity, which enables us to provide you with improved services. We also use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.

We use cookies to:

  • Help remember and process the items in the shopping cart.
  • Understand and save user’s preferences for future visits.
  • Keep track of advertisements.
  • Compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future. We may also use trusted third party services that track this information on our behalf.

You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser (like Internet Explorer) settings. Each browser is a little different, so look at your browser’s Help menu to learn the correct way to modify your cookies.

If users disable cookies in their browser:

If you disable cookies off, some features will be disabled It will turn off some of the features that make your site experience more efficient and some of our services will not function properly.

However, you can still place orders.

Third Party Disclosure

We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information unless we provide you with advance notice. This does not include website hosting partners and other parties who assist us in operating our website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential. We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect ours or others’ rights, property, or safety.

However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.

Third party links

We do not include or offer third party products or services on our website.

Google

Google’s advertising requirements can be summed up by Google’s Advertising Principles. They are put in place to provide a positive experience for users. https://support.google.com/adwordspolicy/answer/1316548?hl=en

We use Google AdSense Advertising on our website.

Google, as a third party vendor, uses cookies to serve ads on our site. Google’s use of the DART cookie enables it to serve ads to our users based on their visit to our site and other sites on the Internet. Users may opt out of the use of the DART cookie by visiting the Google ad and content network privacy policy.

We have implemented the following:

  • Google Display Network Impression Reporting

We along with third-party vendors, such as Google use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to compile data regarding user interactions with ad impressions, and other ad service functions as they relate to our website.

Opting out:
Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising initiative opt out page or permanently using the Google Analytics Opt Out Browser add on.

California Online Privacy Protection Act

CalOPPA is the first state law in the nation to require commercial websites and online services to post a privacy policy. The law’s reach stretches well beyond California to require a person or company in the United States (and conceivably the world) that operates websites collecting personally identifiable information from California consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals with whom it is being shared, and to comply with this policy. – See more at: http://consumercal.org/california-online-privacy-protection-act-caloppa/#sthash.0FdRbT51.dpuf

According to CalOPPA we agree to the following:

Users can visit our site anonymously
Once this privacy policy is created, we will add a link to it on our home page, or as a minimum on the first significant page after entering our website.
Our Privacy Policy link includes the word ‘Privacy’, and can be easily be found on the page specified above.

Users will be notified of any privacy policy changes:
• On our Privacy Policy Page
Users are able to change their personal information:
• By logging in to their account

How does our site handle do not track signals?

We honor do not track signals and do not track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place.

Does our site allow third party behavioral tracking?

It’s also important to note that we do not allow third party behavioral tracking

COPPA (Children Online Privacy Protection Act)

When it comes to the collection of personal information from children under 13, the Children’s Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, the nation’s consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online.

We do not specifically market to children under 13.

Fair Information Practices

The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.

In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur:

We will notify the users via email
• Within 7 business days

We also agree to the individual redress principle, which requires that individuals have a right to pursue legally enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or a government agency to investigate and/or prosecute non-compliance by data processors.

CAN SPAM Act

The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.

If at any time you would like to unsubscribe from receiving future emails, you can email us at and we will promptly remove you from ALL correspondence.

Contacting Us

If there are any questions regarding this privacy policy you may contact us using the information below.
Vapomins Vertriebsgesellschaft mbH

Johannes Schmid

Gollierstrasse 70, 80339 München

M: [email protected]

T: (+49) 089 215 406 870