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privacy policy

Unless otherwise stated below, the provision of your personal data is neither legally nor contractually required, nor is it necessary for the conclusion of a contract. You are not obliged to provide the data. Failure to provide the data has no consequences. This only applies if no other information is provided in the subsequent processing operations.
"Personal data" means any information relating to an identified or identifiable natural person.


server log files
You can visit our websites without providing any personal information.
Every time you access our website, usage data is transmitted to us or our web host/IT service provider through your Internet browser and stored in protocol data (so-called server log files). This stored data includes, for example, the name of the page accessed, the date and time of access, the IP address, the amount of data transferred and the requesting provider.
The processing is carried out on the basis of Art. 6 (1) (f) GDPR due to our overriding legitimate interest in ensuring the trouble-free operation of our website and improving our offering.

Your data will be transferred to Canada, among other places. The EU Commission has issued an adequacy decision for data transfers to Canada.

contact

responsible person
Please contact us if you wish. The person responsible for data processing is: Daniel Redder, Am Postbahnhof 23, 10243 Berlin Germany, +49 (0) 30 50560753, redder@tru-cosmetics.de

customer's initiative contact via email
If you initiate business contact with us by email, we will only collect your personal data (name, email address, message text) to the extent you provide it. The data processing serves to process and answer your contact request.
If the contact serves to carry out pre-contractual measures (e.g. advice in the event of interest in purchasing, preparation of an offer) or concerns a contract already concluded between you and us, this data processing is carried out on the basis of Art. 6 (1) (b) GDPR.
If contact is made for other reasons, this data processing is carried out on the basis of Art. 6 Para. 1 lit. f GDPR due to our overriding legitimate interest in processing and answering your request. In this case, you have the right to object to this processing of personal data concerning you based on Art. 6 Para. 1 lit. f GDPR at any time for reasons arising from your particular situation.
We only use your email address to process your request. Your data will then be deleted in compliance with statutory retention periods unless you have consented to further processing and use.

Collection and processing when using the contact form
When you use the contact form, we only collect your personal data (name, email address, message text) to the extent you provide it. The data processing serves the purpose of establishing contact.
If the contact serves to carry out pre-contractual measures (e.g. advice in the event of interest in purchasing, preparation of an offer) or concerns a contract already concluded between you and us, this data processing is carried out on the basis of Art. 6 (1) (b) GDPR.
If contact is made for other reasons, this data processing is carried out on the basis of Art. 6 Para. 1 lit. f GDPR due to our overriding legitimate interest in processing and answering your request. In this case, you have the right to object to this processing of personal data concerning you based on Art. 6 Para. 1 lit. f GDPR at any time for reasons arising from your particular situation.
We only use your email address to process your request. Your data will then be deleted in compliance with statutory retention periods unless you have consented to further processing and use.


customer account orders

customer account
When you open a customer account, we collect your personal data to the extent specified there. The data processing serves the purpose of improving your shopping experience and simplifying order processing. The processing is carried out on the basis of Art. 6 Paragraph 1 Letter a of GDPR with your consent. You can revoke your consent at any time by notifying us, without affecting the legality of the processing carried out on the basis of the consent until the revocation. Your customer account will then be deleted.

Collection, processing and transfer of personal data when placing orders
When you place an order, we only collect and process your personal data to the extent that this is necessary to fulfil and process your order and to process your enquiries. The provision of the data is necessary for the conclusion of the contract. Failure to provide the data means that no contract can be concluded. The processing is carried out on the basis of Art. 6 Para. 1 lit. b GDPR and is necessary for the fulfilment of a contract with you.
Your data will be passed on, for example, to the shipping companies and dropshipping providers you have chosen, payment service providers, service providers for order processing and IT service providers. In all cases, we strictly adhere to the legal requirements. The scope of data transmission is limited to a minimum.
Your data will be transferred to Canada, among other places. The EU Commission has issued an adequacy decision for data transfers to Canada.


Reviews Advertising

Data collection when writing a comment or review
When you comment on/rate an article or post, we only collect your personal data (name, email address, comment text) to the extent you provide it. The processing serves the purpose of enabling a comment/rate and displaying comments/rates.

By submitting the comment/review, you consent to the processing of the transmitted data. The processing is carried out on the basis of Art. 6 Paragraph 1 Letter a of GDPR with your consent. You can revoke your consent at any time by notifying us, without affecting the legality of the processing carried out on the basis of the consent until the revocation. Your personal data will then be deleted.

When your comment is published, the name and email address you provided will be published.

Use of the email address for sending newsletters
We use your email address, regardless of the contract processing, exclusively for our own advertising purposes to send newsletters, provided that you have expressly consented to this. The processing is carried out on the basis of Art. 6 Paragraph 1 Letter a of GDPR with your consent. You can revoke your consent at any time without affecting the legality of the processing carried out on the basis of the consent until the revocation. You can unsubscribe from the newsletter at any time by using the corresponding link in the newsletter or by notifying us. Your email address will then be removed from the mailing list.

Using Brevo (formerly Sendinblue)
We use the service of Sendinblue GmbH (Köpenicker Straße 126, 10179 Berlin; “Brevo”) to send the newsletter as part of order processing.

We pass on the information you provide when registering for the newsletter (email address, first and last name if applicable) to Brevo. The data processing serves the purpose of sending the newsletter and its statistical evaluation.
In order to evaluate newsletter campaigns, the email newsletters sent contain a 1x1 pixel graphic (tracking pixel) and/or a tracking link. This allows us to determine whether you have opened the newsletter and whether you have clicked on any integrated links. In this context, your personal data such as IP address, browser type and device as well as the time of opening may also be collected. Usage profiles can be created from this data under a pseudonym. The data collected is not used to identify you personally. The data collected is only used for statistical evaluation to improve newsletter campaigns.
Your personal data is processed on the basis of Art. 6 (1) (f) GDPR due to our overriding legitimate interest in a targeted, promotionally effective and user-friendly newsletter system. You have the right to object to this processing of personal data concerning you at any time for reasons arising from your particular situation.
Further information and Brevo’s privacy policy can be found at: https://www.brevo.com/de/legal/privacypolicy/ .


inventory management

use of an external inventory management system
We use a merchandise management system to process the contract as part of order processing. For this purpose, your personal data collected as part of the order will be sent to
Shopify
transmitted.


payment service providers

Using PayPal Express
We use the PayPal Express payment service from PayPal (Europe) S.à.rl et Cie, SCA (22-24 Boulevard Royal L-2449, Luxembourg; "PayPal") on our website. The data processing serves the purpose of being able to offer you payment via the PayPal Express payment service.

To integrate this payment service, PayPal must collect, save and analyze data (e.g. IP address, device type, operating system, browser type, location of your device) when you visit the website. Cookies can also be used for this purpose. The cookies enable your browser to be recognized.
The use of cookies or similar technologies takes place with your consent on the basis of Section 25 Paragraph 1 Sentence 1 TTDSG in conjunction with Art. 6 Paragraph 1 Letter a of GDPR. The processing of your personal data takes place with your consent on the basis of Art. 6 Paragraph 1 Letter a of GDPR. You can revoke your consent at any time without affecting the legality of the processing carried out on the basis of the consent until the revocation.
By selecting and using PayPal Express, the data required for payment processing will be transmitted to PayPal in order to be able to fulfill the contract with you using the selected payment method. This processing is carried out on the basis of Art. 6 Para. 1 lit. b GDPR.
Further information on data processing when using the PayPal Express payment service can be found in the associated privacy policy at https://www.paypal.com/de/webapps/mpp/ua/privacy-full?locale.x=de_DE#Updated_PS

Using PayPal Check-Out
We use the PayPal Check-Out payment service from PayPal (Europe) S.à.rl et Cie, SCA (22-24 Boulevard Royal L-2449, Luxembourg; "PayPal") on our website. The data processing serves the purpose of being able to offer you payment via the payment service. By selecting and using payment via PayPal, credit card via PayPal, direct debit via PayPal or "Pay later" via PayPal, the data required for payment processing will be transmitted to PayPal in order to be able to fulfill the contract with you using the selected payment method. This processing is carried out on the basis of Art. 6 Para. 1 lit. b GDPR.

Credit card via PayPal, direct debit via PayPal & "Pay later" via PayPal
For individual payment methods such as credit card via PayPal, direct debit via PayPal or “Pay later” via PayPal, PayPal reserves the right to obtain a credit report based on mathematical-statistical procedures using credit agencies. To do this, PayPal transmits the personal data required for a credit check to a credit agency and uses the information received on the statistical probability of a payment default to make a balanced decision about the establishment, implementation or termination of the contractual relationship. The credit report may contain probability values ​​(score values) that are calculated on the basis of scientifically recognized mathematical-statistical procedures and whose calculation includes, among other things, address data. Your legitimate interests are taken into account in accordance with the statutory provisions. The data processing serves the purpose of the credit check for the initiation of a contract. The processing is carried out on the basis of Art. 6 Para. 1 lit. f GDPR due to our overriding legitimate interest in protection against payment default if PayPal makes advance payments.
You have the right to object to this processing of personal data concerning you based on Art. 6 (1) (f) GDPR at any time by notifying PayPal for reasons arising from your particular situation. The provision of the data is necessary for the conclusion of the contract with the payment method you have requested. Failure to provide the data means that the contract cannot be concluded with the payment method you have selected.

third-party providers
When paying using a third-party payment method, the data required for payment processing is transmitted to PayPal. This processing is carried out on the basis of Art. 6 Para. 1 lit. b GDPR. To carry out this payment method, the data may then be passed on by PayPal to the respective provider. This processing is carried out on the basis of Art. 6 Para. 1 lit. b GDPR. Local third-party providers can be, for example:

  • Sofort (SOFORT GmbH, Theresienhöhe 12, 80339 Munich, Germany)
  • giropay (Paydirekt GmbH, Stephanstr. 14-16, 60313 Frankfurt am Main)


purchase on account via PayPal
When paying using the purchase on account payment method, the data required for payment processing is first sent to PayPal. To carry out this payment method, the data is then sent by PayPal to Ratepay GmbH (Franklinstrasse 28-29, 10587 Berlin; "Ratepay") in order to be able to fulfill the contract with you using the selected payment method. This processing is carried out on the basis of Art. 6 Para. 1 lit. b GDPR. Ratepay may carry out a credit check on the basis of mathematical-statistical procedures (probability or score values) using credit agencies in accordance with the process already described above. The data processing serves the purpose of credit checks for the initiation of a contract. The processing is carried out on the basis of Art. 6 Para. 1 lit. f GDPR due to our overriding legitimate interest in protecting against payment default if Ratepay makes advance payments. Further information on data protection and which credit agencies use Ratpay can be found at https://www.ratepay.com/legal-payment-dataprivacy/ and https://www.ratepay.com/legal-payment-creditagencies/ .

Further information on data processing when using PayPal can be found in the associated privacy policy at https://www.paypal.com/de/webapps/mpp/ua/privacy-full .


cookies
Our website uses cookies. Cookies are small text files that are stored in the Internet browser or by the Internet browser on a user's computer system. When a user visits a website, a cookie can be stored on the user's operating system. This cookie contains a characteristic string that enables the browser to be uniquely identified when the website is visited again.
Cookies are stored on your computer. You therefore have full control over the use of cookies. By selecting the appropriate technical settings in your Internet browser, you can be notified before cookies are set and decide individually whether to accept them, as well as prevent the cookies from being stored and the data they contain from being transmitted. Cookies that have already been stored can be deleted at any time. However, we would like to point out that you may then not be able to use all of the functions of this website to their full extent.
The links below will tell you how to manage (including deactivate) cookies in the most important browsers:

Technically necessary cookies
Unless otherwise stated in the privacy policy below, we only use these technically necessary cookies for the purpose of making our offer more user-friendly, effective and secure. Furthermore, cookies enable our systems to recognize your browser even after you change pages and to provide you with services Some functions of our website cannot be offered without the use of cookies. For these, it is necessary that the browser is recognized even after changing pages.
The use of cookies or comparable technologies is based on Section 25 Paragraph 2 TTDSG. The processing of your personal data is based on Art. 6 Paragraph 1 Letter f GDPR due to our overriding legitimate interest in ensuring the optimal functionality of the website and a user-friendly and effective design of our offering.
You have the right to object to the processing of personal data concerning you at any time for reasons related to your particular situation.
Use of GDPR Legal Cookie
We use the consent management tool GDPR Legal Cookie from beeclever GmbH (Universitätsstraße 3, 56070 Koblenz a. Rh.; "beeclever") on our website. The tool enables you to give your consent to data processing via the website, in particular the setting of cookies, as well as to exercise your right to withdraw consent you have already given.
The purpose of data processing is to obtain and document the necessary consent for data processing and thus to comply with legal obligations. Cookies can be used for this purpose. The following information, among others, can be collected and sent to beeclever: anonymized IP address, date and time of consent, URL from which the consent was sent, anonymous, random, encrypted key, consent status. This data will not be passed on to other third parties.
The data processing is carried out to fulfill a legal obligation on the basis of Art. 6 (1) lit. c GDPR.
Further information on terms of use and data protection at beeclever can be found at: https://gdpr-legal-cookie.com/pages/terms-conditions and at https://gdpr-legal-cookie.com/pages/datenschutzerklarung.

Use of Google Analytics 4
We use the web analysis service Google Analytics from Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland; “Google”) on our website.

The data processing serves the purpose of analyzing this website and its visitors as well as for marketing and advertising purposes. For this purpose, Google will use the information obtained on behalf of the operator of this website to evaluate your use of the website, to compile reports on website activities and to provide the website operator with other services related to website activity and internet usage.
The following information may be collected, among others: IP address, date and time of the page visit, click path, information about the browser you use and the device you use, pages visited, referrer URL (website from which you accessed our website), location data, purchasing activities. The IP address transmitted by your browser as part of Google Analytics is not merged with other data from Google.
Google uses technologies such as cookies, web storage in the browser and tracking pixels, which enable an analysis of your use of the website.
The information generated in this way about your use of this website is usually transferred to a Google server in the USA and stored there. For the USA, there is an adequacy decision of the EU Commission, the Trans-Atlantic Data Privacy Framework (TADPF). Google has certified itself according to the TADPF and is therefore committed to complying with European data protection principles. Both Google and US government authorities have access to your data. Google may link your data with other data, such as your search history, your personal accounts, your usage data from other devices and any other data that Google has about you.
When using Google Analytics 4, the IP address transmitted by your website is automatically collected and processed in an anonymized form. The IP address is shortened beforehand by Google within member states of the European Union or in other contracting states to the Agreement on the European Economic Area.
The use of cookies or similar technologies takes place with your consent on the basis of Section 25 Paragraph 1 Sentence 1 TTDSG in conjunction with Art. 6 Paragraph 1 Letter a of GDPR. The processing of your personal data takes place with your consent on the basis of Art. 6 Paragraph 1 Letter a of GDPR. You can revoke your consent at any time without affecting the legality of the processing carried out on the basis of the consent until the revocation.
Further information on terms of use and data protection can be found at https://policies.google.com/technologies/partner-sites and at https://policies.google.com/privacy?hl=de&gl=de .

We also use the Google Signals service in this context. Google Signals enables cross-device tracking. Your data can therefore be analyzed across devices if you have activated "personalized advertising" in your account settings and your devices are linked to your Google account. This makes it possible to recognize which device you are using to search for products and return later to complete purchases on another device, such as a tablet.
The cross-device reports created in this context only contain aggregated data. We therefore only receive statistics created on the basis of Google Signals. To prevent data collection and storage by Google Signals across devices, you can deactivate the "personalized ads" function in the settings of your Google account. You can find more information at https://support.google.com/ads/answer/2662922?hl=de .
Further information on data processing and data protection regarding Google Signals can be found at https://support.google.com/analytics/answer/7532985?hl=de .

Plug-ins and Others

Using Google Tag Manager
We use the Google Tag Manager of Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland; "Google") on our website.
This application manages JavaScript tags and HTML tags that are used to implement tracking and analysis tools in particular. The data processing serves the purpose of needs-based design and optimization of our website.
The Google Tag Manager itself does not store cookies, nor does it process personal data. However, it does enable the triggering of additional tags that can collect and process personal data.
Further information on terms of use and data protection can be found here .

use of social plug-ins
We use social network plug-ins on our website. The integration of social plug-ins and the data processing that takes place in this way serves the purpose of optimizing the advertising for our products.
When social plug-ins are integrated, a link is established between your computer and the servers of the provider of the social network and the plug-in is displayed on the page by a message to your browser, provided you have expressly consented to this. Both your IP address and the information about which of our pages you have visited are transmitted to the provider's servers. This applies regardless of whether you are registered with the social network or logged in. Data is also transmitted for unregistered or unlogged users. If you are connected to one or more of your social network accounts at the same time, the information collected can also be assigned to your corresponding profiles. When you use the plug-in functions (e.g. by pressing the button), this information is also assigned to your user account. You can prevent this assignment by logging out of your social media accounts before visiting our website and before activating the buttons.
The use of cookies or similar technologies takes place with your consent on the basis of Section 25 Paragraph 1 Sentence 1 TTDSG in conjunction with Art. 6 Paragraph 1 Letter a of GDPR. The processing of your personal data takes place with your consent on the basis of Art. 6 Paragraph 1 Letter a of GDPR. You can revoke your consent at any time without affecting the legality of the processing carried out on the basis of the consent until the revocation.
The social networks named below are integrated into our website using social plug-ins. Further information on the scope and purpose of the collection and use of data as well as your rights and options for protecting your privacy can be found in the linked data protection notices of the providers.

Facebook of Meta Platforms Ireland Limited (4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland)
Meta Platforms Ireland and we are jointly responsible for the collection of your data when the service is integrated and the transmission of this data to Facebook. The basis for this is an agreement between us and Meta Platforms Ireland on the joint processing of personal data, in which the respective responsibilities are specified. The agreement can be accessed at https://www.facebook.com/legal/controller_addendum . According to this, we are particularly responsible for fulfilling the information obligations according to Art. 13, 14 GDPR, for compliance with the security requirements of Art. 32 GDPR with regard to the correct technical implementation and configuration of the service and for compliance with the obligations under Art. 33, 34 GDPR, insofar as a breach of the protection of personal data affects our obligations under the agreement on joint processing. Meta Platforms Ireland is responsible for enabling the rights of data subjects in accordance with Art. 15 - 20 GDPR, for complying with the security requirements of Art. 32 GDPR with regard to the security of the service and for complying with the obligations under Art. 33, 34 GDPR, insofar as a breach of the protection of personal data affects the obligations of Meta Platforms Ireland under the joint processing agreement.
Your data may be transferred to the USA. For the USA, there is an adequacy decision from the EU Commission, the Trans-Atlantic Data Privacy Framework (TADPF). Meta has certified itself according to the TADPF and is therefore committed to complying with European data protection principles.
For more information about the collection and use of data by Facebook, your rights in this regard, and options for protecting your privacy, please see Facebook's privacy policy at https://www.facebook.com/about/privacy/ .
Instagram of Meta Platforms Ireland Limited (4 Grand Canal Square, Dublin 2, Ireland):
https://help.instagram.com/155833707900388

Your data may be transferred to the USA. For the USA, there is an adequacy decision from the EU Commission, the Trans-Atlantic Data Privacy Framework (TADPF). Meta has certified itself according to the TADPF and is therefore committed to complying with European data protection principles.

Pinterest from Pinterest Inc. (635 High Street, Palo Alto, CA, 94301, USA)
https://policy.pinterest.com/de/privacy-policy
Your data may be transferred to the USA. For the USA, there is an adequacy decision of the EU Commission, the Trans-Atlantic Data Privacy Framework (TADPF). Pinterest is not certified according to the TADPF.


use of Google Maps
We use the function for embedding Google Maps from Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland; “Google”) on our website.
The function enables the visual representation of geographical information and interactive maps. When the pages in which Google Maps are integrated are accessed, Google also collects, processes and uses data from visitors to the websites.
Your data may also be transferred to the USA. For the USA, there is an adequacy decision from the EU Commission, the Trans-Atlantic Data Privacy Framework (TADPF). Google
has certified itself according to the TADPF and is therefore committed to complying with European data protection principles.
Your personal data is processed on the basis of Art. 6 (1) (f) GDPR due to our overriding legitimate interest in designing the website in a needs-based and targeted manner. You have the right to object to this processing of personal data concerning you at any time for reasons arising from your particular situation.
For more information about the collection and use of data by Google, please see Google's privacy policy at https://www.google.com/privacypolicy.html . There you also have the option of changing your settings in the data protection center so that you can manage and protect the data processed by Google.


use of YouTube
We use the function for embedding YouTube videos from Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland; “YouTube”) on our website. YouTube is an affiliated company of Google LLC (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; “Google”).
The function displays videos stored on YouTube in an iFrame on the website. The "Extended data protection mode" option is activated. This means that YouTube does not store any information about visitors to the website. Only when you watch a video is information about it transmitted to YouTube and stored there. Your data may be transmitted to the USA. For the USA, there is an adequacy decision from the EU Commission, the Trans-Atlantic Data Privacy Framework (TADPF). YouTube has certified itself according to the TADPF and is therefore committed to complying with European data protection principles.
Your personal data is processed on the basis of Art. 6 (1) (f) GDPR due to our overriding legitimate interest in designing the website in a needs-based and targeted manner. You have the right to object to this processing of personal data concerning you at any time for reasons arising from your particular situation.
For more information about the collection and use of data by YouTube and Google, your rights in this regard and options for protecting your privacy, please see YouTube's privacy policy at https://www.youtube.com/t/privacy .


Use of Google Fonts
We use Google Fonts from Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland; “Google”) on our website.

The data processing serves the purpose of uniform display of fonts on our website. In order to load the fonts, a connection is established to Google servers when the page is accessed. Cookies may be used for this purpose. Your IP address and information about the browser you use are processed and sent to Google. This data is not linked to your Google account.
Your data may be transferred to the USA. For the USA, there is an adequacy decision of the EU Commission, the Trans-Atlantic Data Privacy Framework (TADPF). Google has certified itself according to the TADPF and is therefore committed to complying with European data protection principles.
Your personal data is processed on the basis of Art. 6 (1) (f) GDPR due to our overriding legitimate interest in a user-friendly and aesthetic design of our website. You have the right to object to this processing of personal data concerning you based on Art. 6 (1) (f) GDPR at any time by notifying us, for reasons arising from your particular situation.
Further information on data processing and data protection can be found at https://www.google.de/intl/de/policies/ and at https://developers.google.com/fonts/faq .


Rights of data subjects and storage period

duration of storage
After the contract has been fully processed, the data will initially be stored for the duration of the warranty period, then taking into account statutory retention periods, in particular those under tax and commercial law, and then deleted after the deadline has expired, unless you have consented to further processing and use.


rights of the data subject
If the legal requirements are met, you have the following rights under Art. 15 to 20 GDPR: Right to information, to rectification, to erasure, to restriction of processing, to data portability.

Furthermore, according to Art. 21 Para. 1 GDPR, you have the right to object to processing based on Art. 6 Para. 1 f GDPR and to processing for direct marketing purposes.

right to lodge a complaint with the supervisory authority
According to Art. 77 GDPR, you have the right to complain to the supervisory authority if you believe that the processing of your personal data is not lawful.


You can lodge a complaint with the supervisory authority responsible for us, which you can reach using the following contact details:

Berlin Commissioner for Data Protection and Freedom of Information
Friedrichstr. 219
Visitor entrance: Puttkamerstr. 16 – 18 (5th floor)
10969 Berlin
Tel.: +49 30 138890
Fax: +49 30 2155050
Email: mailbox@datenschutz-berlin.de


right of objection
If the personal data processing listed here is based on our legitimate interest in accordance with Art. 6 (1) (f) GDPR, you have the right to object to this processing at any time with effect for the future for reasons arising from your particular situation.
Once you have objected, the processing of the data in question will be stopped unless we can demonstrate compelling legitimate grounds for the processing which outweigh your interests, rights and freedoms, or if the processing serves to assert, exercise or defend legal claims.

last updated: July 13, 2023