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 Privacy Policy

Status: 05.05.2021

1. Foreword

Irrespective of whether you are a customer, potential customer, job applicant or visitor to our website: We (hereinafter: PRYM, we) take the protection of your personal data very seriously. So, what does this actually mean?

In the following we give you an insight into which personal data we collect from you, for what purpose and in what form we process them. Moreover, you will be given a summary of your rights under the applicable data protection law. In addition, we provide you with details of the person to contact, if you have any other questions.

1.1. Who are we?

As a controller within the meaning of the applicable data protection laws, we, Prym Fashion GmbH, based in

Zweifaller Strasse 130
52224 Stolberg (Rheinland)
E-Mail: data-protection@prym.com

take all the measures required under applicable data protection law to guarantee the protection of your personal data. We have required our employees to maintain confidentiality, each of our data security measures uses state-of-the-art technology and the company data protection officer ensures compliance with the "Privacy Policy".

For all questions concerning data processing in our company and the safeguarding of your rights you may contact our data protection officer free of charge using the following contact details:

Data Protection Officer
2B Advice GmbH
Joseph Schumpeter Allee 25
53227 Bonn
Tel: +49 (228) 926165 120
PRYM@2b-advice.com

2. Scope of the Privacy Policy

The subject of data protection is personal data. According to art.4 (1) GDPR, this is any information relating to an identified or identifiable natural person. This includes information such as name, mailing address, e-mail address or telephone number, and usage data (e.g. your IP address, if it is not shortened), where applicable.

The processing of personal data as meant by this legal definition is understood to be activities such as the capture, collection, organisation, collating, storing, updating or amendment, the reading, querying, use, disclosure by transfer, dissemination or any other form of provision, the checking or linking, the restriction, blocking, erasure or destruction of personal data.

Personal data are all information, which relates to an identified or identifiable natural person.

This privacy policy covers the personal data of customers, potential customers, job applicants and visitors.

This privacy policy applies to all websites and online presences for which Prym Fashion GmbH is responsible. Some pages may contain links to external companies to which this privacy policy does not extend.

3.    Use of your Personal Data, general information

When you access the Prym Fashion GmbH, your browser transmits certain information to our web server for technical reasons in order to provide you with the information you have requested. We do not request any further personal data from our website's visitors to access our website. Personal data that you share with us via a website (e.g. your email address or your applicant details) are solely processed for correspondence with you and for the purpose for which you made the information available to use (such as providing our services).

If you use our services and other services, we only collect and store your personal data if it is necessary to provide the service or to execute a contract. For this, it may be necessary to pass on your personal data to companies that we use to provide the service or execute the contract. These include, for instance, transportation companies or other services.

After complete contract execution, your data will be blocked and deleted according to fiscal and commercial law guidelines, unless you have expressly agreed to further use of your data.

If you have signed up for our newsletter with your email address, we also use your email address for advertising purposes until you unsubscribe from the newsletter. You may unsubscribe from the newsletter at any time by sending a message or using the appropriate link in the newsletter.

Furthermore, we ensure that we will not pass on your personal data to other companies, unless we are legally obligated to do so or with your prior consent.

4. Which personal data do we process?

We collect your personal data when you contact us, for example as a potential customer or a customer. This may occur, for instance, because you express an interest in our products, register for our online services, contact us through our communication channels or when you use our products or services in the context of existing business relationships.

We process the following types of personal data:

  • Information on personal identification
    • e.g. first name and surname, address data, e-mail address, telephone number, fax number, sex, title
  • Order data
    • e.g. customer number, order number, invoice data
  • Company-related data
    • e.g. company name, department, activity
  • Data on your online behaviour
    • e.g. IP addresses, user names, data on your visit to our website, to the customer portals or to the app, actions performed on our website and on the customer portals, place of access
  • Information on your interests and requirements, which you communicate to us
    • e.g. via our contact form or other communication channels
  • Further data on your customer complaints
    • You are entitled to contact us with regard to customer complaints through our Prym Fashion website. For this we need your e-mail address, names, address data, customer group, telephone number, article number, amount claimed, a detailed description of the fault; all other information is voluntary. The data listed above, which must be provided, are needed by us, so that we can process your complaint with the maximum of efficiency and are able to contact you to make enquiries. In the case of a replacement we need these details also to be able to send you the replacement.
  • Technical Data
    • For technical reasons when you visit our websites data are always transferred from your computer. For example, these include the date and time of your access to the Prym website, the type of browser and settings and the operating system, the amount of data transferred, the site last visited and the access status.
    • These data are collected as a matter of routine, but they are not personal data.
    • In addition, your IP address is usually transferred; in exceptional cases this may be personal data.
  • Information on your professional career
    • e.g. vocational training, previous employers, other qualifications

and other information comparable to these data categories.

4.1. Sensitive Data

Sensitive data within the meaning of the General Data Protection Regulation, i.e. special categories of personal data such as information on health, political opinions, religious beliefs, trade union membership are not collected by this communication channel.

4.2. Personal Data of Minors

The personal data of children or minors are collected only if the latter have a customer account with us, register in the careers portal, use our communication channels or the app. In general our offers are not directed at minors. If we realise that we have processed the personal data of minors without the consent of the legal guardians, this data is immediately erased.

4.3. Use of cookies

Cookies are files, which are deposited from our website or from the customer portals onto your computer during your visit to the site. These files store information, which make your use of this site more efficient. For further information on the cookies we use on our website please refer to the cookie policy under the following link: https://www.prym-fashion.com/en/cookie-policy/

5. For what purpose do we process your personal data – and on what legal basis

5.1. Performance of a contract

We process your data, in order to be able to perform our contracts. This applies also to information, which you disclose to us in pre-contractual correspondence. The specific purposes of the data processing depend on the respective product and the request made and may also be used to analyse your needs and to check which products and services you are interested in.

5.1.1. Implementation of the contractual relationship

To implement the contractual relationship we need your name, address, telephone number and e-mail address, so that we can contact you.

5.1.2. Provision of goods and services

We also need your personal details, in order to be able to check which products we are able and authorised to provide to you and whether we are able and authorised to offer those products and services.

You will find details of the respective purposes for the processing of your data in the contractual documents and in our General Terms and Conditions of Business.

5.1.3. Complaints form

In the event of a complaint we need the following data on your identity: form of address, first name, surname, e-mail, in order to be able to process you request; any other information provided is voluntary. Insofar as absolutely necessary, your data are forwarded, where applicable, to a transport services provider to process the claim. Apart from this, your data are not forwarded to third parties.

5.1.3. Implementation of the application process

If you apply for an employment post advertised by us, we collect all the data required for this and all the data about yourself, which you provide on a voluntary basis. We process these data to implement the application procedures (Article 6(1) point (b) GDPR (in conjunction with Section 26 German Federal Data Protection Act in the case of Germany)). 

We process the data, which you have sent to us when you made an application to us for employment, in order to check whether your professional qualifications are appropriate for the advertised position. We use your data solely for the application procedures and if a contract is concluded, we transfer these data into your personal file. If we do not come to an agreement with you, your data are erased or destroyed. We shall use the information in your application for no other purpose than for the implementation of the application procedure.

Your data are not transferred to third parties and at the end of the application procedure they are erased, unless we are obliged to retain the data on legal grounds or have a legitimate interest in storing them. Your data will be erased at the latest 6 months after the conclusion of the application procedure. We store your data beyond this date only if you have given consent to their retention to be considered for future employment vacancies.

5.2. In accordance with the balancing of interests: we improve our services and offer you suitable products

Important: You have the right to object at any time to the use of your personal data for this purpose.

5.2.1. For the consolidation and optimisation of customer relations

As part of our efforts to improve our relationship with you we occasionally request you to participate in customer surveys. The results of these surveys allow us to make changes to our products and services, so that they match your requirements more closely.

5.2.2. Data processing and analysis for marketing purposes

Your requirements are important to us and we try to provide you with information on products and services, which exactly match your needs. For this purpose we use the insights gained from our business relationship with you and from market research. The aim of this is essentially to adapt our product proposals to your requirements.

What do we specifically analyze and process? 

  • Results from marketing campaigns, in order to measure the efficiency and relevance of our campaigns;
  • Information on your visit to our website;
  • We analyse the potential need for our products and services.

5.2.3. Measures for your security

The cases, in which we use your personal data, include:

  • We analyse your data to protect you or your company from fraudulent activities. This can occur, if you have become the victim of identity theft or unauthorised parties have obtained access to your user account in some other way.
  • If there are technical problems, our IT Support Department works closely with you to improve the reliability of our web applications. In this respect we analyse records of access to pages, actions performed, etc.
  • to guarantee IT security;

5.2.4 Evidence in case of possible litigation

We also process your personal data to be able to collect evidence and proof in the event of a legal dispute.

5.3. Your consent

Provided that you have given us your consent for the processing of your personal data for one or more specific purposes, we are permitted to process your data. You have the right at any time to withdraw your consent with effect for the future, without incurring any costs other than the transmission costs in accordance with the basic tariffs (cost of an Internet connection). Revocation of the consent does not affect the legality of the data processed up until the revocation.

5.3.1. Forms

5.3.1.1. Contact Form

When we receive a contact request, we need the following data on your identity: form of address, first name, surname, e-mail, in order to be able to process you request; any other information provided is voluntary. Insofar as absolutely necessary, your data are forwarded, where applicable, to a transport services provider to process the enquiry. Apart from this, your data are not forwarded to third parties.

5.3.1.2. Dealer registration form

If you are a dealer, when we receive a contact request, we need the following data on your identity: form of address, first name, surname, e-mail, in order to be able to process you request; any other information provided is voluntary. Insofar as absolutely necessary, your data are forwarded, where applicable, to a transport services provider to process the enquiry. Apart from this, your data are not forwarded to third parties.

5.3.1.3. Comment form

You can contribute to our blog on our inspiration pages via our Prym Fashion website. For this we need your e-mail address and the comment itself; all other information is provided voluntarily. As well as being obliged to provide your e-mail address, which we need to identify you and to respond to enquiries, you may also give your name. This then appears above your comment and makes it possible to reply to your blog contribution itself.

When you have drafted your comment you will receive a confirmation e-mail, in which you confirm your consent to the communication of your data. In this process we log the data and time of the consent, your e-mail address and whether the check box has been selected.

5.3.2 Unsolicited applications

Unsolicited applications are processed on the basis of Article 6(1) point (a) GDPR (your consent).

5.3.3 Newsletter

You may register for our newsletter via our Internet site. In order to dispatch it we need your e-mail address; all other information is voluntary.

We use the data, which you have provided on a voluntary basis in order to send you the newsletter, which corresponds to your interests. In the following we set out for you the individual purposes, for which your voluntarily-provided data are used:

- Selection of topics:

You can select individual topic areas to adapt the newsletter to your interests. We use this selection of topics to send you a newsletter, which corresponds to the topics of interest to you. If you do not make any selection, you will receive the newsletter, which covers all the topic areas.

- Age:

The voluntary provision of your age or age bracket helps us to make the best possible adjustments to the newsletter to suit you and by stating your age you are declaring yourself in agreement that we may use this internally in anonymised form for our newsletter statistics.

- Personal data (form of address, title, first name, surname, country):

The voluntary provision of form of address, title, first name and surname helps us to make the newsletter personal to you. If you do not wish to receive a personal response, you will receive a general approach. If you state your country we use this to be able to send you the newsletter in the language of your country. In addition, by stating your country you are declaring yourself in agreement that we may use this internally in anonymised form for our newsletter statistics.

Our newsletter is not sent to you until you have successfully concluded a double opt-in procedure. You have the right at any time to inspect your declaration of consent or to cancel your subscription to the newsletter. The relevant links are implemented in every cover letter sent out with our newsletter. If you decide to cancel your subscription to our newsletter we will immediately erase your contact data from our newsletter subscription list.

The legislative authorities prescribe specific requirements for consent by electronic means, such as for registration for the newsletter, to be effective. This includes a requirement that we record your declaration of consent. We therefore log the data and time of the consent, the text of the declaration of consent, whether the check box has been selected, your e-mail address and all other voluntarily-provided information. Similarly, we log the date and time when you clicked on the confirmation link and on the link in the confirmation e-mail. We collect these details solely to comply with our legal obligations.

5.3.3.1. Use of Mailchimp

To send out our newsletter we use the US service provider, Mailchimp, a service of the US service provider, Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA. We have entered into a data processing agreement with The Rocket Science Group LLC d/b/a MailChimp, which also includes appropriate safeguards to ensure an adequate level of data protection when transferring data outside the European Economic Area (EEA) (the EU Standard Contractual Clauses). Further information on the data processing agreement is available on: https://mailchimp.com/legal/data-processing-addendum/.

You can consult Mailchimp's data protection provisions in greater detail via the following link: https://mailchimp.com/legal/privacy/.

5.3.3.2. Newsletter Tracking

With our newsletter we send what are known as tracking pixels, which allow us to identify when an e-mail has been opened and to capture clicks on links.

These data are stored and help us to adapt the newsletter to the interests of our readers. This means that we are able to produce a personalised newsletter. If you revoke your consent to receiving the newsletter, your consent to tracking is also withdrawn. If you revoke your consent to receiving the newsletter, your consent to tracking is also withdrawn. 

5.4. Legal provisions

As a company we are subject to an extremely wide variety of legal requirements (e.g. under tax legislation). In order to comply with our legal obligations, we process your personal data to the extent required.

6. Where and why we transfer data

6.1. Use of data within PRYM

Within PRYM we provide access to your personal data only to the departments, which require access to these data, in order to fulfil our contractual or statutory duties or to protect our legitimate interests.

6.2. External use of data PRYM

We are mindful of the protection of your personal data and transfer information on you only if required to do so by legal provisions, if you have given your consent, or to fulfil contractual obligations.

For example, we have a legal duty to transfer your personal data to the following recipients:

  • public authorities or supervisory authorities e.g. tax authorities, Customs authorities; 
  • judicial and law enforcement agencies, e.g. the police, the Courts, the Public Prosecutor's Office
  • barristers, solicitors and notaries, e.g. in legal disputes;
  • accountants and auditors.

So that we are able to fulfil our contractual obligations we cooperate with other companies. These include:

  • transport services providers and shipping companies
  • event organisers and training providers, if you have registered through us for particular trade fairs or events;
  • banks and financial services providers for the transaction of all financial matters.

Our service providers

In order to operate more efficiently, we rely on the services of external service providers, who may receive personal data in order to fulfil specified purposes; these service providers include IT service providers, print and telecommunication service providers, debt collection, consultancy or distribution companies.

Important: We take the greatest care of your personal data!

In order to ensure that our service providers comply with the same data protection standards as our company, we have concluded appropriate order processing contracts with them. Among other matters, these contracts regulate:

  • that third parties may access only those data, which they need to perform the tasks assigned to them;
  • that the service providers allow access to your data only to employees, who have been placed explicitly under an obligation to comply with the regulations of data protection law;
  • that the service providers comply with technical and organisational measures, which comply with data security and data protection;
  • what happens to the data, when the business relationship between the service provider and us is terminated.

In the case of service providers, who are domiciled outside the European Economic Area (EEA), we undertake specific security measures (e.g. by enforcing special contractual clauses), in order to ensure that the data are handled with the same amount of care as in the EEA. We check on a regular basis that all our service providers are complying with our requirements.

Very important: On no account do we sell your personal data to third parties!

6.3. Data protection within the PRYM Group

In order to offer you the best service possible, we occasionally exchange data within the Group. In doing so we guarantee that the applicable regulations of data protection law are complied with and that your personal data are adequately protected at all times.

For this reason we have taken appropriate measures to ensure compliance with data protection within the PRYM Group:

We have concluded contracts with the individual subsidiary companies, which ensure that personal data, which is exchanged within the Group, is always protected.

In accordance with these contracts and the applicable data protection law we transfer personal data to our production and distribution subsidiary companies only for the purposes stated in this privacy policy. In this process we assist our subsidiary companies both in operational terms and in compliance with the technical and organisational measures, which we use in the Group parent company, in order to guarantee the security of your personal data. Where possible, we protect your data by pseudonymisation or anonymisation measures. If subsidiary companies are located outside the EEA, we ensure by means of appropriate measures that the personal data processed there is as adequately protected as in those companies within the EEA.

7.  Are you obliged to provide personal data to us?

In the context of the business relationship between you and PRYM we need the following categories of personal data from you:

  • all the data necessary for accepting and performing a business relationship;
  • data, which are needed for compliance with contractual duties;
  • data, which we are required by law to collect.

Without these data it is impossible for us to enter into or perform any contracts with you. 

8. Erasure periods

Pursuant to the provisions on data protection we store your personal data no longer than we need it for the purposes of the respective processing. Provided that the data are no longer needed to comply with contractual or legal duties, they are erased by us on a regular basis, unless we are required to retain them for a specific period. The following are possible grounds for retaining data for a further period:

  • Duties of retention under commercial or tax law must be complied with: Retention periods take precedence in accordance with the provisions of the national law applicable (for instance retention periods according to the German Commercial Code and the German Tax Code can be up to 10 years).
  • For the preservation of evidence in the case of legal disputes within the framework of the legal provisions on the statute of limitations: for instance, according to the German civil law the statute of limitations can apply for up to 30 years, although the usual limitation period is three years.

9. Your rights

You also have specific rights where the processing of your personal data is concerned. More exact details can be found in the relevant provisions of the General Data Protection Regulation (Articles 15 to 21).

9.1. Right to ACCESS and rectification

You have the right to receive information from us as to which of your personal data we process. If this information is not correct or is no longer correct, you have the right to request that we rectify the data, or where data are incomplete to complete the data. If we have transferred your data to third parties, we notify the appropriate third party in the case of equivalent legal status.

9.2. Right to erasure

Under the following circumstances you can request the immediate erasure of your personal data:

  • if your personal data are no longer required for the purposes, for which they were collected;
  • if you have withdrawn your consent and there is no other legal ground for your data to be processed;
  • if you object to the processing and there are no overriding legitimate grounds for the data to be processed;
  • if your data are processed unlawfully;
  • if your personal data have to be erased to comply with legal duties.

Please note that prior to erasing your data we must check that there are no legitimate grounds for processing your personal data.

9.3. Right to restriction of processing (right to blocking)

You have the right to request us to restrict the processing of your personal data on any of the following grounds:

  • if you contest the accuracy of the data, before we have had the opportunity to make sure of the accuracy of the data;
  • if we process the data unlawfully, but instead of requiring that the data be erased, you request only that the use of the data be restricted;
  • if we no longer need the personal data for the purposes of the processing, but you need the data to establish, exercise or defend legal claims;
  • if you have objected to the processing and have not yet established whether your legitimate interests override ours.

9.4. Right to object

9.4.1. Right to object on a case to case basis

If the processing is in the public interest or is based on a balancing of interests, you have the right on grounds relating to your particular situation to lodge a complaint against the processing. If the objection is upheld, we shall not continue to process your personal data, unless we can demonstrate compelling legitimate grounds for the processing, which override your interests, rights and freedoms or because your personal data serve to establish, exercise or defend legal claims. The objection does not apply to the legality of the processing of the data prior to the lodging of the objection.

9.4.2. Objection to advertising

In the cases, in which your personal data are used for advertising campaigns, you have the right at any time to object to this form of processing. We shall then no longer process your personal data for these purposes.

The objection need not be in any particular form and should preferably be sent to:

Prym Fashion GmbH
Zweifaller Str. 130
52224 Stolberg (Rheinland) 
E-Mail data-protection@prym.com

9.5. Right to data portability

You have the right to receive on request the personal data, which you have provided to us for processing, in a transferable and machine readable format.

9.5.1. Right to lodge a complaint with the supervisory authority (Article 77 GDPR)

We try to respond to your enquires and claims as fast as possible in order to protect your rights accordingly. Depending on the frequency of the enquiries, it may happen that up to 30 days elapse before we are in a position to give you further information on your concerns. If the delay should be longer, we shall notify you in good time of the reasons for the delay and we shall discuss with you how to proceed.

In some cases we are unable or are not permitted to give information. Insofar as legally admissible, we shall share with you the reason for the delay.

If, nevertheless, you are not satisfied with our responses and reactions or consider that we are in breach of applicable data protection law, you have the right to lodge a complaint both with our data protection officer and with the competent supervisory authority. The competent supervisory authority for us is:

Regional Officer for Data Protection and Freedom of Information North-Rhine Westphalia
Kavalleriestr. 2 - 4
40213 Düsseldorf

Telephone: +49 211 / 38424 - 0
Fax: +49 211 / 38424 - 10

9.6. Final provisions

9.6.1. Accepting the Privacy Policy

Your use of this or another Prym Fashion GmbH website, online presence, or an interactive advertising banner constitutes your acknowledgement of this privacy policy and your consent to the General Terms and Conditions on this website.

Please visit our website from time to time for updates on our privacy policy and this general section.

9.6.2. Additional Questions

Please contact our data protection officer at the address listed below for any additional questions you may have.

Data Protection Officer
2B Advice GmbH,
Joseph Schumpeter Allee 25
53227 Bonn

Tel: +49 (228) 926165 120
PRYM@2b-advice.com

9.6.3. Version

This Privacy Policy is dated Mai 05, 2021. Registered customers shall be notified of amendments. Earlier versions of the Privacy Policy are available from our website or from our Data Protection Officer.