PRIVACY POLICY

Thank you for your interest in this Privacy Policy. This Privacy Policy explains which Personal Data we collect from you via our website and shop at www.coshcosh.com, what we use it for, when we delete it and how your data is protected. In addition, we will inform you of the respective legal basis that allows us to process your data. Finally, we will also tell you about your rights in connection with the processing of your data.

What is Personal Data?

Personal Data is information that makes it possible to identify a natural person. This includes in particular, your name, date of birth, address, telephone number, e-mail address, but also your IP address. Anonymous data exists if no personal reference to the user can be made.

What is Processing?

"Processing" means and covers virtually any handling of data.

What law applies?

We will only use your Personal Data in accordance with the applicable data protection laws, in particular Germany`s Federal Data Protection Act (“BDSG”) and the EU's General Data Protection Regulation (“GDPR”), and of course only as described in this Privacy Policy.

Who is responsible for data processing?

The responsible party within the meaning of the BDSG and the GDPR is COSHCOSH, Schönleitnerstraße 4, Germany, (“COSHCOSH”, “we”, “us”, “our”).

If you have any questions about this policy or our data protection practices, please contact us using info@coshcosh.com or write to us at the above address.

Data collection

All Personal Data that we obtain from you will only be processed for the purposes described in more detail below. In particular, we collect Personal Data only if:

  • you have given your consent;
  • the data is necessary for the fulfillment of a contract/pre-contractual measures
  • the data is necessary for the fulfillment of a legal obligation;
  • the data is necessary to protect the legitimate interests of our company and business.
  • We process and store your Personal Data only for the period of time required to achieve the respective processing purpose or for as long as a legal retention period exists (in particular commercial and tax law in accordance with the German Commercial Law (HGB) and Fiscal Code (AO) and others for up to 8 years. Once the purpose has been achieved or the retention period has expired, the corresponding data is routinely deleted.

    Data transfers

    In certain cases, it is necessary to transmit the processed Personal Data in the course of data processing. In this respect, there are different recipient bodies and categories of recipients.

  • Internal

    If necessary, we transfer your Personal Data within COSHCOSH. Of course, we comply with the associated legal framework and ensure that your data is processed properly. Access to your Personal Data is only granted to authorized employees who need access to the data due to their job, e.g., to fulfill your order or to contact you in case of queries.

  • External bodies

    Personal Data is transferred to our service providers in the following instances:

    • in the context of fulfilling your orders, shipping and delivery,
    • to use marketing services and to advertise our products online,
    • to communicate with you,
    • to provide our website and shop, and
    • to state authorities and institutions as far as this is required or necessary.
  • We usually do not transfer Personal Data to countries outside Germany or the EEA. However, if we do, we ensure that processing of your Personal Data is governed by Processing Agreements that include Standard Contractual Clauses to ensure a high level of data protection.

    Security of your data

    In order to protect the data stored with us in the best possible way against accidental or intentional manipulation, loss, destruction or access by unauthorized persons, we use appropriate technical and organizational security measures. The security levels are continuously reviewed in cooperation with security experts and adapted to new security standards.

    Nevertheless, internet-based data transmissions can always have security gaps, so that absolute protection cannot be guaranteed. And databases or data sets that include Personal Data may be breached inadvertently or through wrongful intrusion. Upon becoming aware of a data breach, we will notify all affected individuals whose Personal Data may have been compromised as expeditiously as possible after which the breach was discovered.

    Your Rights and Privileges
  • Privacy rights

    Under the BDSG and GDPR, you can exercise the following rights:

    • The right to access;
    • The right to rectification;
    • The right to erasure;
    • The right to restrict processing;
    • The right to object to processing;
    • The right to data portability;
  • Updating your information

    If you believe that the information we hold about you is inaccurate or request its rectification, deletion, or object to its processing, please do so by contacting us.

  • Withdrawing your consent

    You can withdraw consents you have given at any time by contacting us.

  • Access Request

    In the event you want to make a Data Subject Access Request, please contact us. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days, we will tell you why and when we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we will tell you why.

  • Complaint to a supervisory authority

    You have the right to lodge a complaint about our processing of personal data with a supervisory authority responsible for data protection. The Federal Commissioner for Data Protection and Freedom of Information (BfDI) (www.bfdi.bund.de) is the Federal Commissioner for Data Protection. However, we would appreciate the opportunity to address your concerns before you contact any state commissioner or the BfDI.

  • Processing of your Personal Data
  • Log files

    As mentioned above, we want to provide you with an optimal user experience in our online shop and with our advertisements, which is tailored to your individual needs. To this end, we work together with various service providers and technology providers and use cookies and tracking methods.

    The following data is collected anonymously for the purpose of demand-oriented design and optimization of this website:

    • Information on the device used (e.g., operating system, browser, screen resolution, language set.
    • Information on pages viewed during the website visit (e.g., category or product detail pages)
    • Information within the ordering process (e.g., order number, delivery and payment method, shipping and/or billing address)
    • Information on access data (e.g., entry via email newsletters, other websites or online advertising measures).

    The scope of the stored and processed data is limited purely to the performance of statistical evaluations. Your IP address is made unrecognizable immediately after receipt, which means that it is not possible to assign usage profiles to IP addresses.

    The collection of the data is necessary from a technical point of view in order to continuously optimize the functions as well as the presentation of our website on different devices, operating systems and browsers and to be able to make our offer more interesting for you as a user and is therefore based on the legitimate interest.

  • Cookies and Cookie Consent Management Tool

    As described in our Cookie Policy, we use so-called cookies on our website. As the use of Non-essential Cookies requires in accordance with Germany's Federal Data Protection and Privacy in Telecommunications and Telemedia Act (“TTDSG”) and the EU`s Privacy and Electronic Communications Directive (“PECD”), your consent, we use a cookie consent management tool to obtain and of course document your preferences. Consequently, we process: i) Your consent(s) or revocation of your consent(s); ii) Your IP address; iii) Information about your browser; iv) Information about your device; v) Time of your visit to our website. The basis for processing is our legitimate interest and your consent. For further information on the cookies we use, please refer to our Cookie Policy.

  • Hosting of our website and shop

    We use the hosting services of Shopify, for the purpose of hosting and displaying our website and shop. Shopify does so on the basis of processing on our behalf, and that also means that all data collected on our website and shop is processed on Shopify's servers.The basis for processing is our legitimate interest, and the initiation and/or fulfillment of a contract.

  • Contact options

    We process and store the Personal Data provided in the contact enquiry solely for the purpose of processing and responding to your enquiry and contacting you. If you contact us, we will process the data you provide to respond to you and answer your questions and requests. In doing so, the principle of data economy and data avoidance is observed in that you only have to provide the data that we absolutely need from you in order to contact you. These are usually your first and last name, your email address, the topic selection and the message field itself. In addition, your IP address is processed out of technical necessity and for legal protection. The legal basis for processing is our legitimate interest, the provision or initiation of a contractual service and your consent.

  • Shopping with us

    We process your first name, last name, e-mail address, billing and shipping address for the delivery of your order and the data related to your contract with us to handle the contractual relationship.

  • User account

    It is also possible for you to register for an account. For this purpose, you can choose a password together with your email address, both of which will enable you to log in more easily without having to enter your data again when you make a future purchase or to access your order history. We will hold your data for further orders as long as you have your account with us.

  • Personal Data of Third Parties

    It is also possible for you to register for an account. For this purpose, you can choose a password together with your email address, both of which will enable you to log in more easily without having to enter your data again when you make a future purchase or to access your order history. We will hold your data for further orders as long as you have your account with us.

  • Payment Data

    If you make a purchase your payment will be processed via our payment service providers Shopify (Shopify Pay) and its associated payment methods and PayPal. Payment data will solely be processed through Shopify and we have no access to any Payment Data you may submit. The legal basis for the provision of a payment system is the establishment and implementation of the contract.

  • Newsletter

    We use the services of Mailchimp by Intuit Inc to send our Newsletter and if you subscribe we will use your email address to send you information about products, promotions, news and customer satisfaction surveys. You can find an unsubscribe link at the end of each newsletter. The legal basis is your consent.

  • Promotional use of your data

    We use your data within the legally permissible scope for marketing purposes, e.g., to draw your attention to special promotions and discount offers. In addition, we may draw your attention to comparable offers by email, e.g., we may inform you about exclusive sales, promotions, or special events. The legal basis for processing is our legitimate interest.

  • Data management and customer support

    For optimal customer support, we use first name, last name, e-mail address, and the data related to your contract with us. Your data will be stored on our website and or our customer relationship management system provided by Hubspot. This data processing is based on our legitimate interest in providing our service.

  • Administration, financial accounting, office organization, contact management

    We process data in the context of administrative tasks as well as organization of our business, and compliance with legal obligations, such as archiving using the Google Workspace Services offered by Google. In this regard, we process the same data that we process in the course of providing our contractual services. The processing bases are our legal obligations and our legitimate interest.

  • Economic analyses and market research

    For business reasons, we analyze the data we have on business transactions, contracts, enquiries, browsing behavior etc. The analyses serve us alone and are not disclosed externally and processed using anonymous analyses with summarized and or anonymized values. For this purpose we use both Google Analytics and Shopify Analytics and you can find more information about both in our Cookie Policy. The legal basis is our legitimate interest and your consent.

  • Social Media
  • General

    We are present on social media on the basis of our legitimate interest (Facebook, Instagram, YouTube and TikTok). If you contact or connect with us via social media, we and the relevant social media platform are jointly responsible for the processing of your data and enter into a so-called joint controller agreement. The Personal Data collected when contacting us is to handle your request and the bases are both your consent and our legitimate interest.

  • Market research and advertising

    In addition, your data may be processed for market research and advertising purposes. For example, usage profiles can be created from your usage behavior and the resulting interests. This allows, for example, advertisements to be placed within and outside the platforms that presumably correspond to your interests. You can find more information about our advertising on social media in our Cookie Policy. The legal basis is our legitimate interest.

  • When you visit our profiles and interact with us and others

    When you visit our social media profiles, we, as the operator of the profile, process your actions and interactions with our profile (e.g., the content of your messages, enquiries, posts or comments that you send to us or leave on our profile or when you like or share our posts) as well as your publicly viewable profile data (e.g., your name and profile picture). Which Personal Data from your profile is publicly viewable depends on your profile settings, which you can adjust yourself in the settings of your social media account. The legal basis is our legitimate interest and your consent.

  • Advertising

    We would like to show you interesting advertising outside of our website and use various third-party tools and cookies for this purpose. These collect and process information about your activities on our website - for example, which products you are interested in or which pages you visit. By knowing what you are looking for and how you use our website, we can adapt our advertising to your needs. And thus increase the likelihood that you will also be shown suitable and interesting advertising outside our website.

    We also analyze this data to evaluate the relevance of the advertisements and to optimize the advertisements for you. Through the tools, your browser regularly establishes a connection to the server of the tool provider when you visit our website. For some tools, we have no direct influence on what data is processed by the providers. The following personal data may be processed by third-party providers i) HTTP header information (e.g., IP address, web browser, website URL, date and time); ii) measuring pixel-specific data (e.g., pixel ID and cookie ID); and iii) additional information about visits to our website (e.g., orders placed, products clicked on). The legal bases for processing are our legitimate interest and your consent in case of cookies. For further information, please refer to our Cookie Policy.

    What are cookies?

    Cookies are small text files that are sent to your computer to ensure the technical functionality of the website. We use cookies in some areas of our website to make it easier for you to use the pages and to make them more personalized.

    When trying to understand cookies, it can help to know following terminology:

  • Essential or Necessary cookies. These cookies are essential or necessary to ensure that a website works properly and is secure so that you can navigate a website and use its features. Without these cookies, certain features of a website would not function, and thus you would not be able to use certain services.
  • Optional cookies. These cookies are non-essential for the website to function and require your consent. When it comes to optional cookies the following distinctions are made:
    • Functional cookies or sometimes called convenience cookies. These cookies allow a website to remember the options a user has made (including user ID`s stored, consents given, or languages selected) and other personalization options you have selected when browsing.
    • Analysis and performance cookies, which are used to monitor and improve the function and service of a website. Those can track down problems when using a website, facilitate online surveys, record visitor numbers, and provide analytics metrics.
    • Advertising cookies or targeting cookies. They are used to deliver customized advertising to the user. This can be very convenient, but also very irritating.
  • The TTDSG and PECD require us,

  • to ask for your consent when using specific cookies (in particular any cookie that is not strictly necessary for the operation of the website, for example, Functional cookies, Analysis and performance cookies and Advertising cookies or targeting cookies “Optional cookies”); and
  • to have a legal basis for the use of personal data in relation to cookies, the use of cookies would then be your consent as well as our legitimate interest.
  • What cookies do we use?

    We only use optional cookies with your prior consent. If you are visiting our website for the first time, a banner will appear on our website asking for your consent to use optional cookies. If you consent to this, we will store a cookie on your computer and the banner will not be displayed again for the lifetime of the cookie. Thereafter, or if you actively delete this cookie beforehand, the banner will be displayed again the next time you visit our website in order to obtain your consent again.

    How to control cookies?

    You can set your web browser to disable cookies. Please note that most browsers offer different ways to protect your privacy. If you do not activate or deactivate certain cookies via the browser settings, it is possible that certain functionalities will not be available to you as expected.

    You can configure the use of cookies in your browser settings by following the relevant link Google Chrome, Mozilla Firefox, Microsoft Edge, Opera, Safari at any time or deactivate them completely.

    Please note that if you disable cookies in this way, you will not be able to set new cookies. However, it will not prevent previously set cookies from continuing to work on your device until you clear all cookies in your browser settings.

    Analytics
    Google Analytics

    We use Google Analytics, a web analytics service provided by Google. Google Analytics also uses cookies to enable our website to analyze how users use our website across multiple devices. The information generated by the cookies about your use of our website is transmitted to and stored by Google, including transmission to the United States. The following data is processed through the use of Google Analytics:

  • 3 bytes of the IP address of the called system of the website visitor (anonymised IP address),
  • the website called up,
  • the website from which the user reached the accessed page of my website (referrer),
  • the subpages accessed from the website,
  • the time spent on the website,
  • the frequency with which the website is accessed.
  • Google states that it will not associate your IP address with any other data held by Google. The use of this service is based on your consent.

    Shopify Analytics

    We use Shopify Analytics by Shopify. Shopify Analytics uses cookies, which are text files placed on your device, to help the website analyze how users use our website. The information generated by these cookies, such as the time, place, and frequency of your website visit, including your IP address, is transmitted to Shopify and stored there. In this case, your IP address will already be shortened by Shopify and thus anonymised.

    Shopify will use this information for the purpose of evaluating your use of our website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Shopify may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Shopify's behalf. The use of this service is based on your consent.

    Pixel Cookies and Tags

    We use so-called Pixel Cookies and Tags (“Pixel Cookies”). A Pixel Cookie is an advertising tool and typically consists of a JavaScript code snippet that allows us to understand and track visitors' activity on our website. For this purpose, Pixel Cookies collect and process information about visitors of our website and the device used (so-called event data).

    Event data collected through Pixel Cookies is used for targeting our advertisements and improving ad delivery and personalized advertising. For this purpose, the event data collected on our website by means of Pixel Cookies is transmitted to the relevant operator of the Pixel Cookie and in part, also stored on your device. However, this only happens with your consent, and we and the relevant operator of the Pixel Cookie are considered joint controllers. Nonetheless, for the subsequent processing of the transmitted Event Data, the relevant operator of the Pixel Cookie is the sole controller.

    For more information about how the relevant operator of the Pixel Cookie processes personal data, including the legal basis on which they rely on and how you can exercise your rights against, please refer to the following Privacy Policies: Facebook, Instagram, YouTube and TikTok.

    Opting Out
    Google Analytics

    You can disable tracking by Google Analytics with future effect by downloading and installing the Google Analytics Opt-out Browser Add-on for your current web browser following this link http://tools.google.com/dlpage/gaoptout?hl=en.

    Facebook

    If you do not wish to participate in usage-based advertising through Facebook you can object here: https://www.facebook.com/settings?tab=ads

    Instagram

    If you do not wish to participate in usage-based advertising through Instagram you can change your ad settings by following these instructions: https://help.instagram.com/911879456838933

    TikTok

    If you do not wish to participate in usage-based advertising through TikTok you can change your ad settings by following these instructions: https://www.tiktok.com/safety/en/ads-and-data/

    General

    If you do not wish to participate in our advertising personalization or retargeting/tracking you can object to behavioral advertising at the following websites: Your Online Choices, Digital Advertising Alliance of Canada, Network Advertising Initiative, AdChoices and the European Interactive Digital Advertising Alliance (Europe only).

    Changes

    We are constantly developing and improving our website - and as a result, some of the information in this Privacy Policy is likely to change. We therefore recommend that you read this Privacy Policy again from time to time so that you are informed about the current status.

    Do you have any questions?

    Please contact us using info@coshcosh.com if you have any comments or questions about this policy and/or our use of your Personal Data.

    Effective Date

    This Privacy Policy was last updated on Friday, 12 January 2024.