Privacy Policy

Last updated: May 2022

 

This privacy notice for Nordic Digital Ventures AB (“Company", "we", "us", or "our"), describes how and why we might collect, store, use, and/or share ("process") your information when you use eGarderoben website (“Services"), such as when you

• Visit our website at egarderoben.se, or any website of ours that links to this privacy notice.
• Engage with us in other related ways, including any sales, marketing, or events.

If you have a question regarding this Privacy Policy or data protection at eGarderoben you can reach out to our Privacy Team by sending an email to support@egarderoben.se. Please also send an email to our Privacy Team if you would like to request data access, data deletion, or exercise other data protection rights provided in Art. 15-22 GDPR, including withdrawal of consent to marketing, opt out from newsletter etc. For more information see the sections “Which data protection rights do I have?” and “Contact”.

We offer you various options for reading this Privacy Policy. Initially, you can find very basic information in this section. Then we have sorted this Privacy Policy into topics relevant for you and divided it accordingly into individual chapters. To find out about a specific subject, you can jump directly to individual chapters.

We start each chapter with a short overview at the beginning which briefly summarizes the content of the chapter. If you just want a quick high-level overview of all data processing, it is advisable to read the overviews. If you want to familiarize yourself with the details, you can find more information after the overview section.

We have avoided cross-references wherever possible. That way you get all information coherently explained, regardless of which chapter you are currently reading. If you read this Privacy Policy from start to finish, you may find that parts of the text are repeated.

Applicable services and offers in this Privacy Policy: we process your data in a similar way in all of our services. This Privacy Policy therefore applies to all benefits and services which we offer our customers. This is true regardless of whether we do this via a computer, in transactions, on a phone, at events or via social networks or other channels. For ease of comprehension, we use the term “services” to summaries this as a “normal case”.

There are also exceptional services where we process your data differently or for specific purposes. This may be due to the nature of a service or country-specific requirements. When we are referring to these cases (that is “deviations from the normal case”), we call them “service-specific” or “country-specific”.

Finally, you should also bear in mind that eGarderoben is owned by Nordic Digital Ventures AB company registered and governed in Sweden under registration number 559101-1068 and head quarter address at Framtidsvägen 10A, 352 22, Växjö, Sweden.

Where we refer below to “eGarderoben”, “we” or “us”, we mean the responsible company which process your data.

What you will learn in this Privacy Policy:

• Which data eGarderoben
• What we do with this data and what it is needed
• Which data protection rights and options you
• Which technologies and data we use to personalize and coordinate our services in order to offer you a secure, simple, seamless, and individual shopping
• Which technologies and data we use for advertising, including the tracking technologies we use.

1.  Which data does eGarderoben process?

eGarderoben offers you a wide range of services, which you can also use in a wide range of ways. Depending on whether you contact us online, by phone or otherwise and on which services you use, various data from different sources may come into play. Much of the data we process is provided by you yourself when you use our services or contact us, for example when you register and provide your name or email or address. We do, however, also receive technical device and access data which is automatically collected when you interact with our services. This may, for example, be information on which device you are using. We collect further data using our own data analyses (e.g., within the framework of market research studies and customer valuations). We may also receive data on you from third parties, for example for credit rating agencies and payment service providers.

When we talk about “your data”, we are referring to personal data. This includes all information which allows us to identify you straight away or by combining it with other information. Examples: Your name, your telephone number, your customer number, order numbers or your email address. All information which cannot be used to identify you (even by combining it with other data) is classified as non-personal data.

Non-personal data is also referred to as anonymous data. If we combine your personal data with anonymous data, all the data in this record counts as personal data. If we delete the personal data from a piece of information or a record on your person, the remaining data in this record no longer counts as personal data. This procedure is referred to as anonymization. The following generally applies: If we request that you share specific personal information with us, you may of course refuse to do this. You can decide which information you share with us. We may, however, be unable to provide you with the desired services (at least not optimally). For example, you cannot have a package delivered without giving a delivery address. If specific information is required in connection with a service (mandatory information), we will inform you by marking it accordingly.

1.1.       Profile information

Profile information is personal and demographic information on your person (so-called master data), along with your individual interests, which you share with us when registering for a customer account. Your profile data includes, for example:

• Your first and last names
• Your contact details
• Your preferences, e.g., in relation to brands, product types or styles
• Demographic information such as your gender, age, and place of residence

Mandatory information is usually your name, your email address, and a password you choose yourself. Your email address and the password will later constitute your login details.

Other mandatory information may also be required for the use of access-restricted, fee-based, or personalized services, such as your date of birth or your gender (e.g., to transfer you to the relevant eGarderoben shop page for your gender) or your favorite brands and clothing styles.

Profile data may also include further information on your person and your interests. These may be collected in the process of registering for the service, or subsequently. This is the case, for example, if you later add voluntary information to your profile or wish to use your customer account to register for a service which requires additional mandatory information.

If you are logged into your customer account, you can view your personal data there and can usually edit it directly there, e.g., to update your address after a move.

1.2.       Contact details

If you contact us, we collect your data. Depending on how you contact us (e.g., by phone or by email), your contact details may include your name, postal addresses, telephone numbers, email addresses, detail on your social network profiles (for example we receive your Facebook ID if you contact us via Facebook), usernames and similar contact details.

1.3.       Shopping information

If you order something from eGarderoben, we collect your shopping data. Depending on the type of purchase and processing status, shopping data may include the following information:

• Order number
• Details on the purchased items (name, size, color, price etc.)
• Payment method information
• Delivery and billing addresses
• Messages and communication relating to purchases (e.g., notice of revocation, complaints, and messages to customer service)
• Delivery and payment status, e.g., “completed” or “dispatched”
• Return status, e.g., “successfully completed”
• Information on service providers involved in executing the contract (for order purchasing perhaps shipment numbers of parcel services)

1.4.       Payment details

We offer you the common payment methods in online retail – in particular, advance payment, credit card, PayPal, or invoice. We do not collect or save the payment details shared by you to execute the payment. These data are controlled by the corresponding payment gateway which you select at checkout page. However, we may receive further or partial payment details from external payment service providers and credit agencies which we work with in executing payments and carrying out credit checks. We only forward information to our payment service providers which is necessary for processing payment.

Payment details include:

• Preferred payment method
• Billing addresses
• IBAN, BIC, account number, sort code or other banking information
• Credit card details
• Creditworthiness data

The payment details also include other information directly connected to payment processing and credit checking. This applies, for example, to information which external payment service providers use for identification such as your PayPal ID (if you are paying with PayPal).

Cooperation with external payment service providers and credit agencies is on a country-specific basis, to take country-specific features and requirements into account. Under “Who is my data forwarded to?” section you can find information on external payment service. There you can also find special privacy policies which we provide you with on behalf of the relevant payment service providers and credit agencies.

1.5.       Interest information

When you interact with our services, data arises which we use to find out which content, topics, products, product types, brands, or styles you are interested in. For example, we can use shopping data, wish list content and your age (if this information is available to us) and comparison with users with similar features to find out which styles and product categories you are interested in. Thus, we can show the products which will probably be most relevant to you first when you perform a search.

Along with the interests you have directly shared with us, we can also derive your interests from other data we have collected. If, for example, you repeatedly visit a particular area of the eGarderoben shop, we can conclude your interests from your access data by means of usage analysis (e.g., we can presume that you might be interested in dresses if you frequently visit the category “Dresses” or order products from this category).

For this purpose, we also receive demographic information and statistics on our users from our external advertising partners (such as age, gender, region), as well as device and access data and interests. We take care that our advertising partners only provide eGarderoben with aggregate, encrypted and anonymous data, so that we cannot assign the data to any specific person, especially any specific user. This information may help us to understand our users better, perhaps within the framework of customer structure analyses and user segmentation.

You can find further information on the processing of your data for advertising purposes under “How does eGarderoben use my data for marketing?”.

1.6.       Messages and conversation content

If you communicate with us regarding products (e.g., product evaluations) and other topics by phone, post, social media, contact forms or any other medium, we collect the content of your messages.

We may forward your messages to the department responsible for your concerns, perhaps to partner companies or manufacturers. If your messages are forwarded to another company (e.g., if you provide us with feedback on the manufacturer of a product), you of course have the option to tell us that the data should only be used by eGarderoben. If so, we will not forward your information to the responsible party or department, or will only do so without your personal information, provided that your concerns can be processed in this way.

If you transmit messages to us for other users via functions provided for this purpose (e.g., product evaluations), we may publish these within the scope of our services.

eGarderoben also uses social network services such as Facebook, Instagram, and Pinterest to communicate with customers and users. We use these popular platforms to offer you further contact and information options beyond our in-house communication channels. Please bear in mind, however, that we do not have any influence on the terms of use for social networks and the services they offer, and only limited influence on their data processing. We therefore ask you to carefully check which personal data you share with us via social networks. We cannot influence the behavior of social media operators, other users or third parties who may work with the operators of the social networks or also use these services.

1.7.       Social network data

eGarderoben maintains profile pages on various social networks. Additionally, eGarderoben services may incorporate social networking features. These may be messenger services and so-called social plug-ins or social logins such as "Sign in with Facebook". If you are in direct contact with us through our social media profiles or if you use social networking features integrated into our services and you are a member of the respective social network, we may receive data from the social network operator that allows you to be identified. Usually, we can see the following data:

• Your public profile information stored on the respective social network (e.g., name, profile picture)
• Details of the device type you are using
• The account ID of your profile on the respective network (e.g., Facebook ID)

Please also refer to the notes on the processing of social network data related to social network features under “Info on websites” and “Information about Social Media Pages”.

eGarderoben currently uses the Facebook and Pinterest services and social plug-ins for the following social networks:

• Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”). The link to Facebook's privacy policy is available here: Facebook's Data Policy.
• Pinterest Inc., 635 High Street, Palo Alto, CA, USA (“Pinterest”). The link to Pinterest's privacy policy is available here: Pinterest's Privacy Policy.

1.8.       Site data

For particular purposes, we also collect data on your device’s current location when you use our services. Two different technologies are used for this.

If you approve your device’s location services for a browser, eGarderoben processes the location data collected by your device and provided to us in order to provide you with location-specific services.

We also collect location data derived from your device’s IP address (down to the city level). An anonymized IP address shortened to three characters is used for this purpose. Therefore, this cannot be used to identify your internet connection or device.

This procedure (so-called geo-localization) is used by us and many other online shops, for example to identify fraud and suspicious orders (e.g., it may be suspicious in particular situations if an order from your customer account uses an IP address from a country where you have never previously made any orders) or setting the proper language and currency on the website.

1.9.       Photos and other personal content

Some of our service-specific features allow you to share photos and other personal content with us or other users, in order to communicate with us or other users or to personalize services (e.g., by uploading a profile picture, or using the eGarderoben comments and reviews).

1.10.   Information for campaigns and surveys

If you take part in a campaign or survey (e.g., customer satisfaction survey for market research purposes) offered by eGarderoben, we may ask you for personal information.

For example, if you take part in a competition, we generally ask you for your name and email address, so that we can inform you if you win and to ensure that each participant only takes part in the competition once.

We may ask you for further information for some campaigns and surveys. This may be the case, for example, if we carry out a campaign with a partner and the partner needs information on you in order to make the prize available to you. In such cases we will, however, always inform you separately about the information required and how we use it.

1.11.   Device and access data

When using online and mobile services, it is inevitable that technical data will be generated and processed in order to provide the features and content offered and to display them on your device. We refer to this data as "Device and Access Data". Device and Access Data are created whenever online and mobile services are used. It does not matter who the provider is. Device and Access Data are therefore created, for example, when using:

• Websites
• Apps
• Social media pages
• Email newsletters (i.e., if your newsletter interaction is recorded)
• Location-based services

eGarderoben collects device and access data for online and mobile services offered by eGarderoben itself. Secondly, eGarderoben may receive device and access data from online and mobile services of other companies, as long as they are social media or advertising partners of eGarderoben or participate in the same online advertising networks (e.g., the "Google Network"). Additional information is available under “How does eGarderoben use my data for advertising?” and “Information about Social Media Pages”.

Device and Access Data includes the following categories:

• General device information, such as information on the device type, operating system version, configuration settings (e.g., language settings, system authorizations), information on internet connection (e.g., name of the mobile data network, connection speed) and on the app used (e.g., name and version of the app).
• Identification data (IDs), such as session IDs, cookie IDs, unambiguous device ID numbers (e.g., Google advertising ID, Apple Ad ID), third party account IDs (if you use social plug-ins or social logins or pay by PayPal) and other common internet technologies, to facilitate recognition of your web browser, your device, or a particular app installation.
• Access data automatically transmitted by apps and web browsers whenever you access web servers and databases (within the framework of so-called HTTP requests). This is standardized information on the required content (such as the name and file type of a retrieved file) as well as further information on server access (such as amount of data transferred and error codes), on your device (e.g., device type, operating system, software versions, device identifications, IP address, the site previously visited and the time of access).

2.  What does eGarderoben use my data for?

eGarderoben processes your data in accordance with all applicable data protection laws. Of course, we observe the principles of data protection law for the processing of personal data. We therefore generally only process your data for the purposes explained to you in this Privacy Policy or shared when we collect the data. These are mainly purchase processing and the provision, personalization, and development as well as security of our services. We also use your data within the framework of the strict Swedish and European data protection law, but also for other purposes such as product development, scientific research (especially in the areas of machine learning, artificial intelligence, and deep learning) and market research, for the optimization of business processes, the needs-based design of our services and personalized advertising.

In this chapter, we also inform you of the legal basis on which we process data for the individual purposes. Depending on the legal basis for our processing of your data, you may have additional data protection rights alongside your permanent rights such as the right to information. For example, in individual cases you have the right to object to the processing of your data. You can find further information under “Which data protection rights do I have?”

2.1.       Purchase processing and provision of online, local, and personalized services

We process your data in the necessary scope to fulfil contracts and to provide and execute further services requested by you, as described in this Privacy Policy. The purposes of the necessary data processing therefore depend on the purpose of the contract agreed with you (including our General Terms and Conditions and any service-specific terms and conditions or terms of use) or services requested by you. The most important purposes are:

• The provision, personalization, and needs-based design of our services such as the eGarderoben shop (including the respective websites, apps and cross-device and cross-platform functions).
• The execution of customer programs such as eGarderoben Gift Card and eGarderoben personal promotions.
• The execution of purchase agreements and customer service including dispatch and payment processing, claim management as well as the processing of returns, complaints, and warranty claims.
• The provision of messages, reports, newsletters, and other direct communication, insofar as these are an integral component of our contractual services or the services requested by you. For example:
• You can request email information on the availability of out-of-stock items in the eGarderoben shop.
• The guarantee of the general security, operability and stability of our service including protection from attacks.
• Non-promotional communication with you on technical, security-related, and contractually relevant subjects (e.g., fraud warnings, account blocking or contractual changes).
• The mediation of contracts via our trading and sales platform, perhaps within the framework of the eGarderoben partner.
• The issuing, redemption, delivery of eGarderoben gift cards.
• The execution of campaigns and competitions.

The processing of payments for execution of purchase agreements are provided by external payment gateways including but not limited to Stripe, PayPal, and Shopify. You can find information on external payment providers under section “Who is my data forwarded to?”.

Legal basis:

Insofar as the purpose relates to the execution of a contract agreed with you or the provision of a service requested by you, the legal basis is Article 6 (1) b GDPR. Otherwise, the legal basis is Article 6 (1) f GDPR, whereby we may use your personal data for the above purposes if we deem it necessary to do so for our legitimate interests.

2.2.       Shopping personalization

We process your data for the provision of comfortable and useful services which correspond as well as possible to your needs and interests. Because the eGarderoben shop’s range encompasses thousands of products and multiple brands, it is necessary that we present our content and offers in a needs-based manner so that you can find products you are actually interested in. This requires a user-specific evaluation of the relevance of products and content.

To personalize shopping in the eGarderoben shop we use device and access data which we collect for usage analysis. Alongside this, we also use device and access data which we receive from advertising partners while you visit the eGarderoben shop. If you are logged in with your customer account while visiting the eGarderoben shop, we also use profile data, interest data and shopping data to personalize your shopping experience. We refer to this form of shopping personalization as on-site optimization. Only such shopping personalization allows us to present you with suitable search results, product suggestions, style recommendations and other content corresponding to your actual interests. Without such shopping personalization, as carried out today by many online shops as standard, your search for relevant products would be less convenient and more protracted and the utility of our range for you would be lower. Shopping personalization does not, of course, prevent you from accessing all content. It does, however, allow you to see content which is more relevant to you more quickly.

Legal basis:

The legal basis for the processing of your data for shopping personalization within the framework of personalized services is Article 6 (1) b GDPR. The legal basis for the processing of your data within the framework of on-site optimization is Article 6 (1) f GDPR, whereby our legitimate interests are in the above purposes.

2.3.       Research, machine learning and artificial intelligence

We process the data collected on our customers for market research in the areas relevant to eGarderoben. This includes in particular the research areas of machine learning, artificial intelligence, natural language processing and deep learning. Research at eGarderoben concentrates on solutions to real, everyday online shopping problems and is meant to serve the improvement and development of the existing services range. In this way, for example, we can develop webpages which can suggest products targeted to your interests and needs and recognize styles and assign products which correspond to your actual interests.

In doing this, of course, we observe recognized scientific data protection standards. This also means we only process your data in summarized, anonymized or pseudonymized form for research purposes, for example by replacing all identifiable data such as your name with other values.

Research at eGarderoben includes the following purposes:

• The development of machine learning procedures allowing estimates, prognoses and analysis of the needs and interests of our users.
• The development of technical solutions for real customer problems which our specialist departments and fashion manufacturers encounter in day-to-day business (e.g., difficulties in finding suitable products, reducing the probability of bad buys, sizing).
• The development of technical solutions for optimizing business and logistics processes.
• The development of technical solutions facilitating the improvement and development of shopping personalization and fraud prevention.

Legal basis:

The legal basis for the processing of your data within the framework of the research purposes described above is Article 6 (1) f GDPR, whereby our legitimate interests are in the above purposes.

2.4.       Fraud prevention and selection of payment methods

Prevention of fraud

In order to combat the risk of data security breaches, data pertaining to users of our services is encrypted in transmission. This applies both to ordering and to registering for a customer account. For this we use the coding system SSL (Secure Socket Layer). Encryption prevents third parties from viewing the data. To provide additional protection from external attacks, we rely on special security technologies which constantly check our systems and identify and report anomalies. We also use technical and organizational measures to secure our systems against loss, destruction, unauthorized access, or distribution of customer data by unauthorized persons. In this manner we wish to keep the risk of unauthorized access as low as possible, because protecting your data is our top priority. However, we - like other companies - cannot guarantee absolute protection.

We also use technical and manual procedures for fraud prevention in order to protect us and our users from misuse of data, especially by fraudulent orders. To this end, our payment processing partners summarize and evaluate your device and access data (including IP address, identifiers, user behavior), shopping data and payment details (including address and other creditworthiness data from external credit agencies) as well as the change history of your profile information (e.g., when your delivery address was last changed) under a pseudonym when executing an order. The record is also compared with your previous usage and order habits. We also compare it to general records from all eGarderoben orders involving confirmed or suspected fraudulent actions. This comparison allows us to identify fraud patterns and to prevent fraud and identity theft by comparing patterns. Sometimes when based on our analysis the likelihood of fraud is very high, we may cancel orders or deactivate accounts in order to minimize the risk of fraudulent orders and protect users whose accounts may have been taken over.

In some countries we may offer customers the option to pay for purchases by Invoice or Cash on Delivery. In the event that you select such payment methods, eGarderoben transmits your name and your addresses as provided by you during checkout to external credit agencies. This serves to ensure that you are actually registered and can be reached at the disclosed addresses.

If the payment processing’s security system suspects attempted fraud or an increased risk of fraud, the relevant procedure will be forwarded to the eGarderoben fraud team for manual investigation. Appropriate preventative measures will be taken in view of the risk of fraud (e.g., temporary blocking of the customer account or restriction of payment methods offered).

These providers collect and process data, with help from cookies and other tracking technology, to establish the end device used by the user as well as further data on the use of the website. There is therefore no assignment to a specific user.

Over the course of the order process on our website, we request a risk assessment for the user's end device from the database of providers. This risk assessment on the likelihood of attempted fraud considers, amongst other things, whether the end device has logged on using different service providers, whether the end device has a geo-reference which frequently changes, how many transactions were affected on the end device and whether a proxy connection is used.

Legal basis:

If your data is processed to prevent fraud at your expense, the legal basis is Article 6 b GDPR. This processing of your data otherwise occurs on the basis of Article 6 (1) f GDPR, based on our legitimate interest and that of other users in the identification and prevention of fraud and clarification of criminal offences.

Choice of payment methods

We show you the available payment methods for a purchase at checkout stage. When deciding on the payment types offered, the total costs for the specific payment type for eGarderoben as well as the availability of the payment type in the relevant country are considered. It may be the case that we no longer offer certain payment types, which are associated with higher costs, risks, or increased returns for us, to our customers who typically return things at a rate higher than the average or who place incredibly small orders. The modification of available payment types contributes to lower return rates, which is more sustainable and more economic. At the same time, our customers continue to have the option of using our services, as every customer is offered at least one possible payment type and can then complete the purchase.

The risk level of offered payments is assessed separately for each payment method in the form of an estimate. If the risk assessment yields a positive result, we can offer all the payment methods we generally offer. Otherwise, we will only offer you particular payment methods. Factors which may influence the availability of a payment method include:

• The combination of name and address could not be found. This may result from typing errors, moves, marriage or a change of district.
• You have given a delivery address, packing station or company address differing from the billing address.
• There are still open claims against you.
• There have been payment disruptions with particular payment methods in the past.

The risk assessment will not mean that you are not offered any payment method. If you are not in agreement with the payment methods offered, you can inform us of this in writing by letter or email at support@egarderoben.se. We will then check the decision again, taking your viewpoint into account.

Legal basis:

The legal basis for processing of your data is Article 6 (1) f GDPR, based on our legitimate interest in avoiding default risks.

2.5.       Advertising and market research, data analysis

We use your data, also within the framework of data analysis, for advertising and market research, in particular for the following purposes:

• Classification into various target and user groups within the framework of market research (user segmentation).
• Findings on various target groups and their respective usage habits and shopping interests.
• The production of findings on demography, interests, our users’ shopping, and usage habits as well as the marketing on these findings within the framework of advertising services provided to third parties.
• The early identification of trends in the areas of fashion and online shopping.
• The execution of advertising to existing customers.
• The execution of direct marketing, e.g., in the form of newsletters.
• The planning, execution and success monitoring of advertising corresponding to the interests of the target groups being addressed (personalized advertising).
• Findings as to how our services are used (usage analysis).
• The marketing of the above findings within the framework of advertising services for advertising customers.

Depending on the purpose, we use the data we have stored for data analysis. For example, we use summarized (aggregated), statistical, depersonalized (anonymized) profile information or data which can only be assigned to persons via further intermediate steps (pseudonymized profile information) as well as shopping and device and access data in order to understand and analyze purchasing processes using data analysis. This gives us anonymous or pseudonymized findings on our users’ general usage behavior.

We process your data on the basis of balancing of interests to protect our legitimate interests or those of third parties, eGarderoben’s legitimate interest or that of third parties in data processing derives from the relevant purposes and is, unless otherwise indicated, of a competitive and economic nature.

Please note that eGarderoben on IOS devices, after 10 June 2021 no longer shares any data with third parties for marketing purposes. In case a particular IOS system still offers features that involve data sharing with a third party for marketing purposes, your data will only be shared if you click “agree” on an iOS tracking prompt.

Legal basis:

If data processing for the above purposes occurs with your consent, the legal basis is Article 6 (1) a GDPR (consent). This data processing data otherwise occurs on the basis of Article 6 (1) f GDPR, whereby the legitimate interests are for the above purposes.

2.6.       Product and technology development

We use your data for product and technology development including the development and improvement of personalized services. In doing this we use aggregated, pseudonymized or anonymized data and machine learning algorithms, perhaps from our research, which facilitate estimates, prognoses, and analysis in the interests of our users. In this way, for example, we can develop pages which can suggest products targeted to your interests and needs and recognize styles and assign products which correspond to your actual interests. Data is processed in relation to product and technology development particularly for the following purposes:

• The development and improvement of personalized services and technologies for data analysis, advertising, and personalized online shopping.
• The development of technologies and concepts to improve IT security, prevent fraud and improve data protection e.g., by pseudonymization, encryption and anonymization technologies.
• The development and testing of software solutions for the optimization of necessary business and logistics processes.

Legal basis:

The legal basis for the processing of your data for product and technology development purposes is Article 6 (1) f GDPR, whereby our legitimate interests are in the above purposes.

2.7.       Business management and business optimization

We transmit and process your data where necessary for administrative and logistical processes and to optimize business processes within eGarderoben in order to design these in a more efficient and legally secure way and to fulfil our contractual and legal obligations (e.g., retention obligations under commercial and tax law). Many systems and technologies are shared within eGarderoben website. This allows us to offer a more economical, secure, unified, and personalized service. Therefore, various departments within eGarderoben have access to your data in so far as this is necessary for the fulfilment of the purposes named in this Privacy Policy.

Data processing for business management and business optimization also includes, for example, the following purposes:

• The execution and improvement of customer service.
• The prevention and clarification of criminal offences.
• Guaranteeing the security and operability of our IT systems.

 Legal basis:

The legal basis for the processing of your data for business management and optimization is Article 6 (1) f GDPR, whereby our legitimate interests are in the above purposes. Where we process your data on the basis of legal specifications, e.g., retention obligations and money laundering tests under tax law, the legal basis is Article 6 (1) c GDPR.

2.8.       On the basis of your consent

If you have given us your consent for the processing of personal data, your consent is the primary basis of our data processing. Which data we process on the basis of your consent, depends on the purpose of your consent. Typical purposes include:

• Subscription to a newsletter.
• Participation in surveys and market research studies.
• The transmission of your data to third parties or to a country outside the European Union.
• Processing of your location data by Google Maps in specific cases, such as offering information on the nearest pick-up points of your order.

You can withdraw consent at any time with effect for the future by e-mail or letter.

If the relevant service supports this function, you can adjust and withdraw consent to receive newsletters and other notifications in the preferences. You can find the link to the preference in each newsletter. Each newsletter also contains a corresponding unsubscribe link. You can find further instructions under “Which data protection rights do I have?”.

2.9.       Other purposes

If data protection law allows it, we can use your data for new purposes such as carrying out data analyses and developing our services and content without your consent. It is a prerequisite for this that these new purposes which the data is to be used for were not fixed or foreseeable when the relevant data was collected, and the new purposes are compatible with the purposes for which the relevant data was originally collected. For example, new developments in the legal or technical sphere and new business models and services may lead to new processing purposes.

 

3.  Personalized services

The development and provision of personalized functionalities and services for you is our top priority. We offer you an individual shopping experience and a range tailored to your individual interests, regardless of location, time and devices used. The processing of your data to personalize our service is therefore an integral part of eGarderoben’s service. For example:

• If you create a wish list in the eGarderoben website, you can view and edit this later on.
• If you search for products on the eGarderoben website, we save your search terms. This allows us to show the results first which are probably particularly relevant to you when you search the eGarderoben website in future.
• If you place a product in the basket, we can give you recommendations on the selection of a suitable clothing size on the basis of your previous orders and returns.
• If you have subscribed to our newsletter, we can present you with products which fit your previous orders.
• We also consider your previous orders when recommending new products to you that may fit your shopping preferences.

3.1.       What are personalized services?

Personalized services allow us to offer you better, more practical, and more secure services. To this end we use the data we have stored about you in order to determine your needs and interests. On this basis we can offer you more relevant content corresponding to your needs and interests. Of course, you still have access to all content. Personalization allows you to see content, which is more relevant to you more quickly, or content is specially presented to you (e.g., in the form of individual product recommendations).

3.2.       Why do I need a customer account?

Most of our personalized services require you to set up a customer account so that we can save data we collect on you at a central location.

3.3.       Which data is saved on my customer account?

Data which we collect about you is saved on your customer account, along with your customer number (customer ID). The customer number is a randomly generated sequence of numbers which does not contain any personal data. Your data is associated with your customer number, in order to link you to your customer account. The customer number also functions as a pseudonym.

3.4.       Which data is used for personalization?

Personalized content is generally selected on the basis of all data stored on your customer account. If device and access data is used which is not saved on your customer account, these are only pseudonymized for the relevant personalization (so e.g. in connection with your customer number, but not in connection with your named or other directly identifying profile data) for the duration of the usage.

We do not collect, save, and use the following data in personalization:

3.4.1.     Creditworthiness data

3.4.2.     Information for campaigns and surveys

3.4.3.     Notifications (e.g., from customer service)

3.4.4.     Messages and communication with our customer support

3.5.       Your options

If personalization is based on device and access data, you can prevent the collection of this data by deactivating the collection of this data by tracking tools. Please bear in mind, however, that you will receive less or no personalized content and services. Please bear in mind that the data used for personalized services are also needed for other purposes (including the provision of our services), in which case the collection of the data required will continue to be collected. However, the advertising presented to you will then not be personalized.

4.  Info on website

We use your data to provide access to the eGarderoben websites. Along with the device and access data collected whenever you use the service, the type of data processed as well as the processing purposes depend especially on how you use the functions and services provided via our services. We also use the data collected when you use our services to find out how our online offering is used. We use this information and other information in the course of shopping personalization to improve our services and for personalized advertising.

4.1.       Providers

You can find the responsible service provider in the imprint of the relevant website.

4.2.       Which data is collected?

We generally collect all the data which you directly share with us via our services.

Device and access data

Whenever you access our services and databases, we collect device and access data and record it in so-called server log files. The IP address it contains is anonymized shortly after the end of the relevant session as soon as storage is no longer required to maintain the functionality of the relevant website.

If it is available and activated on your device, we also collect a device-specific ID number (e.g., a so-called “promo ID” if you are using an Android device or an “ad ID” if you are using an Apple device). This device ID is issued by the manufacturer of your operating system and can be read by websites and apps and used to present content on the basis of your usage habits. If you do not want this, you can deactivate it at any time in your device’s browser settings or system settings.

Login

We set up password-protected personal access for users who register for a customer account or another service. If you do not log out again after logging in with your login details, most services automatically keep you logged in. Depending on the type of service, a cookie or similar technology is used for this. This function allows you to use part of our services without having to log in again every time. For security reasons, however, you will be asked to enter your password again if, for example, you want to change your profile information or submit an order. You can find more information under “Personalized services”.

Social plug-ins

Our services may contain social plug-ins (“plug-ins”) from various social networks. These plug-ins allow you, for example, to share content or recommend products. The plug-ins are deactivated as standard and therefore do not send any data. You can activate the plug-ins by clicking on the corresponding button (e.g., “share on social media”). The plug-ins can also be deactivated again with a click. If the plug-ins are activated, your web browser sets up a direct connection to the web servers of the relevant social network. The content of the plug-ins is then transferred by the social network directly to your web browser and integrated by the latter into our website. Integrating the plug-ins allows the social network to receive the information that you have called up the relevant page of our internet offering and can collect your device and access data. If you are logged into the social network, the latter may also assign the visit to your account with the relevant social network. If you interact with the plug-ins, for example by clicking the Facebook “like” button or making a comment, the corresponding information will be transmitted by your browser directly to the social network and stored there. The purpose and scope of the data collection, and the further processing and use of the data by the particular social networks and your rights and configuration options concerning this to protect your privacy, can be found in the Privacy Policy of the respective social networks and websites. You can find the links to these below. Even if you are not registered with the social networks, websites with active plug-ins may send data to the networks. An active plug-in will place a cookie with an ID each time you call up the website. Because your web browser sends this cookie without being asked every time you connect to a server, the social network could in principle create a profile of which websites the user belonging to the ID had called up. And it would also be quite possible to assign this ID to a person, for example if they later registered with the social network.

Facebook and Instagram social plug-ins

We use plug-ins by the social network facebook.com, operated by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA (“Facebook”), on several pages. You can find the link to Facebook’s Privacy Policy here: Facebook’s privacy policy.

Pinterest social plug-ins

We use plug-ins by the social network Pinterest, operated by Pinterest Inc., 651 Brannan Street, San Francisco, CA 94103, USA (“Pinterest”), on several pages. You can find the link to Pinterest’s privacy policy here: Pinterest’s privacy policy.

Social logins

Our services may offer you the option of registering with us directly using your social network accounts. If you wish to use this function, you will first be forwarded to the relevant social network’s offering. There you will be asked to log in with your username and password. Of course, we do not ourselves take note of your login details. If you are already logged in, this step will be skipped. The relevant social network then notifies you and asks you to confirm which data are transmitted to us (e.g., public profile, friends list, email address and current residence). We use the data transmitted to create your customer account, but will not, of course, save your friends list, for example. No further permanent connection between your customer account and your social network account will take place. We also receive social network data from the providers of the relevant social networks.

Shopping personalization

Our services use the device and access data from the usage analysis, which are collected when you use our service, for shopping personalization. Depending on the type of service, this may include common tracking technologies using tracking pixels and identification cookies or similar Ids (so-called tagging). In addition, our advertising partners may collect your device and access data in this way, in order to provide us with information on your interests and demographic data (such as age, gender, region) during your use of our services. This allows us to present you with advertising and/or particular offerings and services which correspond to your interests (for example product recommendations based on the fact that you have only viewed trainers in the last few days). Our goal when doing this is to make our offering as attractive to you as possible and to present you with advertising corresponding to your interest areas. Of course, you can continue to use all content and functions. This on-site optimization does, however, allow us to first show you content and functions which are more relevant for you. On-site optimization is carried out automatically by our systems, which recognize that users have repeatedly called up products and content from particular categories.

If you do not want on-site optimization, you can deactivate this function at any time. To do this, please deactivate the “Marketing & Retargeting” function in preferences of consent notice.

Info on website cookies

Our websites use cookies. Accepting cookies is not a prerequisite for using our websites. We would, however, like to point out that our websites can only function on a limited basis if you do not accept cookies. You can set your browser up in such a way that cookies are only saved if you agree to this.

What are cookies?

Cookies are small text files which are saved by your web browser, and which save particular settings and data for exchange with our web server.

A distinction is generally made between two different types of cookies, so-called session cookies, which are deleted as soon as you close your browser, and temporary/permanent cookies which are stored for a longer period. Storing this data helps us to design our websites and services for you accordingly and makes them easier for you to use, for example by saving particular entries so that you do not have to repeat them constantly.

Which cookies we use?

The cookies used by our website may come from eGarderoben or our advertising partners. If you only wish to accept the eGarderoben cookies, but not our advertising partners’ cookies, you can choose the corresponding setting in your browser (e.g., “block third-party cookies). The help function in your web browser’s menu bar generally shows you have to reject new cookies, and to turn off cookies which have already been received. We recommend that you completely log out after you finish using our website on shared computers which are set to accept cookies and Flash cookies.

Our services use four categories of cookies:

• Strictly required cookies: These cookies are required for optimal navigation and operation of the website. For example, these cookies are used to implement the basket function, such that the goods in your basket stay saved while you continue with the purchase. The necessary cookies also serve to save particular inputs and settings which you have made so that you don’t have to constantly repeat them, and to adapt eGarderoben content to your individual interests. Only limited use of the website is possible without necessary cookies.
• Analytics & statistical cookies: These cookies collect device and access data to analyze the use of our website, such as which areas of the website are used how (so-called surfing behavior), how fast content is loaded and whether errors occur. These cookies only contain anonymous or pseudonymous information and are only used to improve our website and to find out what our users are interested in, and to measure how effective our advertising is. Statistical cookies can be blocked without adversely affecting the navigation and operation of the website.
• Marketing cookies (“tracking cookies”): These cookies contain identifiers and collect device and access data, in order to adapt personalized advertising on eGarderoben websites to your individual interests. Our advertising partners who operate online advertising networks also collect device and access data on our websites. This allows us to display personalized advertising on other websites and in other providers’ apps which fits your interests (so-called retargeting). Marketing cookies can be blocked without adversely affecting the navigation and operation of the website. Shopping personalization may, however, not be possible.
• Functional cookies: these cookies enable our website to offer additional functions and settings. They could be set by us or third-party service providers that we have placed on our website. You can deactivate these cookies, but it will stop the functioning of related services. For example, chat services, comments, and reviews.

4.3.       Online advertising/retargeting

Our website contains cookies and similar tracking technologies from advertising partners which operate an online advertising network. This also allows our advertising partners to collect your device and access data and to present you with personalized advertising on other website and in other providers’ apps targeted to your interests (e.g., advertising based on which products you have previously viewed in the eGarderoben shop).

You can find further information under “How does eGarderoben use my data for advertising?” You can deactivate the processing of your data for retargeting at any time from preferences button on notice bar.

4.4.       Usage analysis

We use common tracking technologies to evaluate device and access data. This allows us to find out how our offering is being used by our users in general. We do this using identification cookies and similar identifiers. This allows us to find out, for example, which content and topics are particularly popular, when our services are used the most, from which regions (down to the city level) our services are used and which browsers and devices our users generally use.

We may also carry out so-called A/B tests in the course of usage analysis. A/B tests are a special kind of usage analysis. A/B testing (also known as split testing) is an approach to comparing two versions of a website in order to find out which version performs better, is more popular or lets users find their desired content quicker. Producing a “version A” and “version B” and testing both versions provides data which makes it easier and faster to make changes to services and content.

You can deactivate the processing of your data for usage analysis at any time from preferences button on notice bar.

 

5.  Information about social media pages

eGarderoben maintains social media profiles on the social networks of Facebook, Instagram, and Pinterest. We regularly publish and share content, offers and product recommendations on our pages. The operators of the social networks record your usage behavior via cookies and similar technologies upon every interaction on our pages. Social media page operators can view general statistics about the interests and demographic characteristics (e.g., age, gender, region) of page visitors. When you use social networks, the nature, scope, and purposes of processing social network data are determined primarily by the social network operators.

5.1.       Provider / Responsible party

eGarderoben, which acts as the content provider of a page, is visible in the Legal Info of the respective page.

The Facebook and Instagram social networks are both provided by Facebook Ireland Ltd., 4 Grand Canal Square, Dublin 2, Ireland ("Facebook").

Insofar as you communicate directly with us via our pages or share personal content with us, eGarderoben shall be responsible for processing your data. An exception applies to the data processing for usage analysis (Page Insights) which is described as follows; in this case, we are jointly responsible with Facebook.

Processing of your data by Facebook

Please note that Facebook also processes your data when you use our pages for their own purposes, which are not covered in this Privacy Policy. We have no influence over these data processing operations of Facebook. In this regard, we refer you to the privacy policy of the respective social networks:

Facebook's Data Policy: https://www.facebook.com/about/privacy/  

Instagram's Privacy Policy: https://help.instagram.com/519522125107875/  

5.2.       Which Data are Collected?

When you visit our pages, eGarderoben collects all communications, content, and other information that you provide us directly, e.g., when you post something on a page or send us a private message. Of course, if you have an account on the social network, we can also see your public information, such as your username, information in your public profile, and content that you share with a public audience. For more information, see "Which data does eGarderoben process”.

5.3.       Usage Analysis (Page Insights)

Whenever you interact with pages, Facebook uses cookies and similar technologies to track the usage behavior of page visits. On this basis, page operators receive so-called "Page Insights". Page insights contain only statistical, depersonalized (anonymized) information about visitors to the page, which can therefore not be assigned to a specific person. We do not have access to the personal information Facebook uses to create Page Insights ("Page Insights data"). Selection and processing of Page Insights data is performed exclusively by Facebook.

Page insights offer us information about how our pages are used, what interests our visitors have in webpages, and what topics and content are particularly popular. This allows us to optimize our page activities, e.g., by better tailoring to the interests and usage habits of our audience when planning and selecting content.

eGarderoben and Facebook share responsibility for processing your data for providing Page Insights. For this purpose, Facebook has a defined agreement about which company fulfils the data protection obligations under the GDPR with regard to Page Insights data processing. You can find the details on Facebook’s information about page insights.

Legal bases:

If you have given consent to the creation of Page Insights data to Facebook, the legal basis is Article 6 (1) a GDPR (Consent). Otherwise, the legal basis is Article 6 (1) f GDPR, whereby our legitimate interests are in the above purposes.

5.4.       Which data protection rights do I have?

Your privacy rights described in this section also apply to the processing of your data in connection with our pages and services.

For the purposes of processing your Page Insights data with Facebook, Facebook is primarily responsible for providing you with information about the processing of your Page Insights data and for enabling you to exercise your privacy rights under the GDPR (e.g., right to object). You can find more information about your data protection rights in connection with Page Insights and how you can exercise them directly with regard to Facebook:

https://www.facebook.com/legal/terms/information_about_page_insights_data

6.  Newsletter

We offer you various newsletter services which include

• Inspirational content such as updates on brands, trends, offers, sales, categories.
• Reminders e.g., when an item on your Wishlist is reduced in price, if items in your bag are forgotten or if you asked for a size reminder.
• Surveys which for example seek to find out whether you liked the items you purchased.
• Personalized recommendations of items we think you might like based on your previous orders and browsing behavior.
• Updates from the styles or brands that you may follow on our site.

If you signed up for newsletters, you would receive some of the newsletter services as described above (depending on the scope of your subscription).

6.1.       How do I register?

When sending out our notifiable newsletters (such as the eGarderoben shop newsletter), we use the so-called double opt-in procedure or single opt-in procedure (country-dependent), i.e., we will only send you the newsletter if you have given explicit prior consent to us activating the newsletter. If a double opt-in is required in your country, you must also have confirmed that the email address you have shared with us belongs to you. For this purpose, we will send you a notification email and ask you to confirm by clicking on one of the links in this email that you are the owner of the email address you have shared with us. We may waive this measure if you have already confirmed to us in this way for another purpose that you are the owner of this email address.

Furthermore, you may receive commercial messages from eGarderoben (subject to competition law) e.g., individual recommendations after your last purchase, without having subscribed to a newsletter. You can find further information about this under “Individual product recommendations by email”.

In order to provide you with more personalized content, eGarderoben also aggregates data based on your engagement with eGarderoben and its services. For example, if you open our newsletters often, we know that you are interested in them and will be able to serve your needs accordingly both in terms of frequency and content of the emails.

6.2.       Unsubscribing

If you no longer wish to receive emails from us, you can unsubscribe at any time by using the unsubscribe link available in every newsletter or in every commercial message you receive from us. You may also send a notification in text form (e.g., email, or letter) for the relevant newsletter.

Feel free to contact support@egarderoben.se to unsubscribe or in case you experience any difficulties.

6.3.       Which data is collected?

If you subscribe to a newsletter, we temporarily store your IP address and save the time of your subscription and confirmation. This way we can prove that you actually subscribed and identify any unauthorized use of your email address.

We collect device and access data when you interact with newsletters, transactional emails, as well as push notifications. For this evaluation, the newsletters contain links to image files stored on our web servers. When you open a newsletter, your email program loads these image files from our web server. We collect the device and access data under a randomly generated ID number (newsletter ID), which we will not use to identify you without your consent. This way we can understand whether and when a newsletter was opened. The links contained in the newsletters likewise contain their newsletter ID so that we can determine which content is read. In order to personalize the communication, we collect open and click data to provide you with relevant communication. We aggregate the data for newsletter ID and connect your newsletter subscription with your customer account in order to personalize newsletter content according to your interests and usage habits and to statistically analyze how our users use the newsletter service.

This shopping personalization is an integral component of the eGarderoben shop newsletter. You may object to the personalization at any time by changing your settings in the “Preferences” section on eGarderoben’s website.

We connect this data to other data which we collect within the framework of usage analysis, as long as you opt in for analytics tracking in the “Preferences” section on our website.

Alternatively, you can deactivate the display of images in your email program. In this case, however, the newsletter will not be displayed to you in full.

7.  Individual product recommendations by email

In connection with our services, we present information and offerings from eGarderoben on the basis of your interests. You may receive a limited number of individual product recommendations, surveys, as well as product review requests from us regardless of whether you have subscribed to a newsletter. In accordance with legal stipulations, we preferentially use the data on your previous orders, to select individual product recommendations.

You can also find further information about the personalization of individual recommendations under “Personalized services”.

If you do not wish to receive any individual product recommendations from us by email, you can informally object to it at any time by clicking the unsubscribe link which you will find in every email, or by sending an email to support@egarderoben.se.

8.  Vouchers & gift cards

We use the data submitted when ordering eGarderoben gift cards to check and process the order and to issue and redeem the gift card. This also includes the recording and processing of the data connected to use of the gift card, especially for fraud prevention.

We also stored the following data for this purpose:

• Date of issue
• Voucher value
• Voucher code
• Personalization data (if you provide this)
• Name of gift card holder (for personal gift cards)
• Time of gift card redemption
• Name of the redeeming party and the customer account ID of the account used for redemption.

9.  How does eGarderoben use my data for advertising?

We and our advertising partners use your data for personalized advertising presented to you in eGarderoben’s services and on other providers’ websites and apps. We and our advertising partners use the prevailing market technologies for this purpose. This allows us to advertise in a more targeted way in order to display as many adverts and offers as possible to you which are actually relevant. This allows us to better meet our users’ needs as regards personalization and discovering new products and to interest you in our service in the long run by providing a more personalized shopping experience.

Please note that eGarderoben on IOS systems released after 10 June 2021 no longer share any data with third parties for marketing purposes. In case a particular IOS app still offers features that involve data sharing with a third party for marketing purposes, your data will only be shared if you click “agree” on an iOS tracking prompt.

9.1.       Advertising formats and channels

The advertising formats used by eGarderoben and eGarderoben’s advertising partners include presentations in the eGarderoben shop (within the framework of on-site and in-app optimization), adverts on social networks (e.g., Facebook ads, Instagram ads, YouTube video ads) and advertising spaces mediated via the online advertising networks used by eGarderoben such as but not limited to DoubleClick by Google or Microsoft Ads network.

eGarderoben does not sell any personal data. When our advertising customers book an advertising format with eGarderoben, they do not receive any data which could be used to contact or identify you without your express consent. Our advertising customers only receive anonymous, aggregated reports with information on the effectiveness and reach of the advertising services we provide. These reports are based on eGarderoben’s own surveys, and sometimes also consider summarized reports which we receive from our advertising partners and social networks. These show, for example, how our advertising services have affected sales to various groups of customers.

9.2.       Information which we use to create target groups

In creating target groups, we use our own findings from data analysis on our users’ usage and purchasing behavior and customers as well as our market research on user segmentation which we apply to the user data collected by eGarderoben. In doing this we especially consider aggregated, pseudonymized or anonymized shopping data, search histories, interest data and demographic profile data as well as device and access data.

Our advertising partners also have the option to provide us with their own data for user segmentation, which was collected by the advertising partners themselves. The advertising partners must undertake only to provide eGarderoben with aggregated, encrypted, or anonymous data, so that we cannot assign the data to any particular person, especially any particular user of the eGarderoben shop. Some target groups are created on the basis of the users’ surfing behavior. This is the case if advertising is only intended to be presented to users who have recently visited a particular website or searched for particular content.

9.3.       How do we use this information in online advertising on the eGarderoben shop

We use the above information within the framework of on-site optimization in order to present you with more relevant information and content when you search for products, call up your feed or visit a product area. On-site and in-app optimization is based on cookies and similar identification technologies for the pseudonymous collection of device and access data. This data is not used to identify you personally, but rather to evaluate your usage pseudonymously. Your data is never permanently combined with other personal data we have stored on your person. This technology allows us to present you with products and/or particular offerings and services with content based on your device and access data (for example advertising geared to the fact that you have only viewed sports clothing in the last few days).

If you do not want on-site optimization, you can deactivate this function at any time.

9.4.       On social networks

If we advertise via advertising formats offered by social networks (e.g., YouTube, Facebook, Instagram), we have the option of forwarding encrypted information on eGarderoben users (e.g., device and access data such as advertising and cookie IDs, email addresses) which we believe belong to an advertising customer’s target group or show particular features (e.g., age group, region, interests).

The relevant social network will then - either on our behalf as an order processor or with the consent of the relevant user - decrypt the transmitted data and display the advertising booked by us to the user as part of his/her existing usage relationship with the relevant social network (if the user is a member of the relevant social network).

If you do not want us to use your data to present you with personalized advertising on social networks, you can deactivate the forwarding of your data.  If you have consented to the forwarding of your data to social networks, you can withdraw your consent at any time.

You may also have the option of deactivating the use of your data for personalized advertising by the social networks you use by directly contacting the relevant providers. For further information, directly contact:

Facebook (Facebook, Instagram):

Information on Facebook adverts

Advertising settings for Facebook

Google (Google advertising network, YouTube, Google search):

Information on Google adverts

Advertising settings for Google

How Google uses information from sites or apps

 

9.5.       Advertising spaces mediated via online advertising networks (retargeting)

Advertising partners who run an online advertising network may use cookies and similar technologies to pseudonymously collect your usage behavior using device and access data on the eGarderoben shop and in other providers’ apps. These advertising partners use the data collected in order to identify the probability of you belonging to the target group we are addressing and take this into account when choosing the adverts on the advertising spaces mediated via their online advertising network. This standard internet technology is referred to as retargeting. Retargeting allows us to run advertising which is as relevant to you as possible and to measure the efficiency and reach of the advertising materials, but also to check our advertising partners’ bills for campaigns we are running.

You can get further information on the operators of the respective advertising spaces and the online advertising networks charged with mediating them. You can find an overview of advertising partners and information on deactivation on their own website.

Please bear in mind that the data used for retargeting is also needed for other purposes (including the provision of our services). The collection of the data used for this is therefore not prevented by deactivation. The advertising presented to you will then not, however, be personalized.

10.       Who is my data forwarded to?

eGarderoben only forwards your data if this is allowed by Swedish or European law. We work particularly closely with certain service providers, for example in the area of customer service (e.g., hotline service providers), with technical service providers (e.g., running computer centers) or with logistics companies (e.g., postal companies such as UPS). These service providers may generally only process your data on our behalf under special conditions. Where we use them to process orders, the service providers only receive access to your data in the scope and for the time period required for provision of the relevant service. If you shop with an eGarderoben partner we forward particular shopping data regarding you to the eGarderoben partner (e.g., your name and your delivery address), so that the eGarderoben partner can send you the goods ordered.

10.1.   eGarderoben partner companies

Many systems and technologies are shared within eGarderoben. This allows us to offer you a more economical, secure, unified, and personalized service. Therefore, companies partnered with eGarderoben which require access to your data to fulfil our contractual and legal obligations, or to fulfil their respective, receive this access.

10.2.   Shipping companies

We work with external shipping companies (e.g., UPS) to deliver orders. These shipping companies receive the following data to execute the relevant order:

• Your name
• Your delivery address
• your post number if applicable (if you wish to have the order delivered to a delivery station)
• your email address if applicable (if the shipping company wishes to inform you of the provisional delivery date by email)
• Your phone number (if the shipping company wishes to inform you of the provisional delivery date by SMS)

10.3.   Technical service providers

We work with technical service providers in order to be able to provide our services. These service providers include, for example, Shopify Inc., Microsoft Ltd., and Trustpilot Inc. If they process your data outside the European Union, this may mean that your data is transmitted to a country with a lower data protection standard than the European Union. In such cases eGarderoben will ensure that the relevant service providers contractually or otherwise guarantee an equivalent data protection level.

10.4.   Payment service providers

eGarderoben offers different payment options, such as advance payment, payment by credit card, payment by PayPal and Klarna payment. For this purpose, payment data can be transferred to payment service providers with whom we work with. You can find more details about processing of personal data by payment service providers in their privacy policies:

10.5.   Social media networks

As part of advertising campaigns, we forward data to social network providers within the scope of data protection law. You can find further information under “How does eGarderoben use my data for advertising?”.

Please note that eGarderoben on IOS systems released after 10 June 2021 no longer share any data with third parties for marketing purposes. In case a particular IOS app still offers features that involve data sharing with a third party for marketing purposes, your data will only be shared if you click “agree” on an iOS tracking prompt.

10.6.   Authorities and other third parties

If we are obliged by an official or court decision or it is for prosecution purposes, we will, if necessary, forward your data to prosecution authorities or other third parties.

11.       Which data protection rights do I have?

You have the following legal data protection rights under the relevant legal conditions: Right to information (Article 15 GDPR), right to deletion (Article 17 GDPR), right to correction (Article 16 GDPR), right to restriction of processing (Article 18 GDPR), right to data portability (Article 20 GDPR), right to lodge a complaint with a supervisory authority (Article 77 GDPR), right to withdraw consent (Article 7 (3) GDPR) as well as the right to object to particular data processing measures (Article 21 GDPR). If you want to exercise your data protection rights, you can reach out to our Privacy Team by sending an email to support@egarderoben.se. For more information see section “Contact”.

Important information:

• In order to ensure that your data is not disclosed to third parties in the course of requests for information, please attach sufficient proof of identity to your request by email or post.
• You can change most of your information yourself in your customer account. For other cases please contact customer service.
• The competencies of the data protection authorities depend on the seat of the data controller. You may, however, contact any data protection authority in any member state of the European Union, in particular at your place of residence, which will forward your complaint to the competent authority. The lead authority competent for eGarderoben is “IMY” the Swedish Authority for Privacy Protection (Integritetsskyddsmyndigheten), Integritetsskyddsmyndigheten, Box 8114, 104 20 Stockholm, Sweden.
• If you have given consent for the processing of your data, you may withdraw it at any time. Withdrawal has no effect on the admissibility of the processing of your data which took place before the withdrawal.
• You may object to the processing of your data for advertising purposes, including direct marketing (including in the form of data analysis) at any time without giving reasons.
• If we are processing your data on the basis of balancing of interests according to Article 6 (1) f GDPR (e.g., the reporting of creditworthiness to an external credit agency), you may object to the processing. When asserting your objection, we ask you to give the reasons why you do not wish us to continue processing your data. In the event of a justified objection, we will check the state of affairs and either stop or adjust the processing or inform you of the urgent reasons worthy of protection why we are entitled to continue the processing.

12.       When will my data be deleted?

We will store your personal data as long as is necessary for the purposes named in this Privacy Policy, especially for the fulfilment of our contractual and legal obligations. We may also store your personal data for other purposes if or as long as the law allows us to store it for particular purposes, including for protection against legal claims.

If you close your customer account, we will delete all the data we have stored regarding you. If it is not possible or necessary to completely delete your data for legal reasons, the relevant data will be blocked for further processing.

Blocking will occur, for example, in the following cases:

• Your order and payment details and perhaps other details are generally subject to various legal retention obligations. The law obliges us to retain this data for tax audits and financial audits for up to ten years. Only then can we finally delete the relevant data.
• Even if your data is not subject to any legal retention obligation, we may refrain in the cases allowed by the law from immediate deletion and instead carry out initial blocking. This applies especially in cases where we may need the relevant data for further contractual processing or prosecution or legal defense (e.g., in the event of complaints). The decisive criterion for the duration of the blocking is then the legal limitation periods. After the relevant limitation periods expire, the relevant data will finally be deleted.

Deletion may be waived in the cases allowed by law if the data is anonymous or pseudonymous and deletion would rule out or seriously hinder processing for statistical purposes.

13.       How does eGarderoben protect my data?

We transmit your personal data securely using encryption. This applies to your order and your customer login. We do this using the coding system SSL (Secure Socket Layer). We also use technical and organizational measures to secure our website and other systems against loss, destruction, access, change or dissemination by unauthorized persons.

14.       Changes to this Privacy Policy

Further development of our and the implementation of new technologies to improve our service for you may require changes to this Privacy Policy. We therefore recommend that you re-read this Privacy Policy from time to time.

15.       Contact

You can reach out to our Privacy Team for general questions on privacy and in order to exercise your data protection rights by sending an email to support@egarderoben.se.

In order to directly contact our Data Protection Officer, please send your inquiry to the following postal address indicating that it is “to the attention of Data Protection Officer”:

 

Nordic Digital Ventures AB

(eGarderoben / Data Protection)

Framtidsvägen 10A

352 22, Växjö

Sweden

support@egarderoben.se

+46 (470) 515 123

16.       Service-specific information

Our data processing may differ from service to service. Here you can find out which service-specific deviations apply.

Information regarding the use of the Messenger-function

We may use a messenger function on our website. Using the messenger function, you can get in touch with our customer service. We store your messages in order to improve our service quality and to respond better to your needs within the scope of this contractual relationship. Through the messenger function, we can provide you with additional support for your enquiries.

The messenger function is used on the basis of article 6 para 1. sentence 1 Lit.b. GDPR in order to provide the service you have requested. We store the data collected through the use of the messenger function. The data is stored for as long as we require for the purposes stated. You can find more information on the criteria for determining the storage period in this data protection information under point “When will my data be deleted?”.

If you decide to use the messenger function, we will process the following data:

• First and Last name
• Age
• Gender
• Place of residence
• Messages in the chat history
• Photos
• The products that are relevant for you/you are interested in

Google Maps

eGarderoben website may use the service of Google Maps, which is provided for users by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland or by Google LLC, 1600 Amphitheatre Parkway Mountain View, CA 94043, USA (together "Google"). This service allows eGarderoben customers to find a nearest pick-up point for orders based on their location. In order for Google Maps to enable this feature, your web browser must make a connection with a server operated by Google, which may be located in the USA.

If you access Google Maps service on our website while you are logged-on in your Google profile, Google may further combine this event with your Google profile. If you do not wish allocation to your Google profile, it will be necessary for you to log out before accessing our contact page. Google will store your data and use them for purposes of advertising, market research and personalized display of Google Maps. You can object to this data collection by contacting Google.

You will find more detailed information on this subject in Google’s Privacy Statement and in the Additional Terms of Service for Google Maps.