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Privacy Policy – Holdit AB
For us at Holdit AB ("Holdit"), it is important that your personal data is handled carefully, responsibly, transparently, and legally. In this privacy policy, we describe how we process personal data about you – if you make a purchase with us or are a member of our customer club. It also describes how we process your personal data when you visit our website, if you have chosen to subscribe to our newsletter, if you participate in our competitions or if we share your posts/pictures on social media or on our website, and if you contact us.
How do we process your personal data – summary
If you make a purchase on our website, we process your personal data to:
manage your purchase;
handle any questions about your purchase, right of withdrawal, returns, and complaints; and
send a request if you want to review your purchase.
If you are a member of our customer club, we process your personal data to:
manage your membership and My account;
manage your points and membership level and show previous and current purchases;
send newsletters and other marketing to you;
save your favorites; and
remind you of products you left in the shopping cart.
If you save your favorites on our website, we process your personal data to offer this feature.
If you have chosen to subscribe to our newsletter, we process your personal data so that you can receive our newsletters.
When you visit our website and have chosen to give your consent, we process your personal data to:
analyze how our website is used with Google's analytics service;
analyze from which partner you found our website to be able to pay correct compensation to our partners; and/or
show you interesting offers from us on other pages you visit using marketing services from Google, Meta (Facebook and Instagram), TikTok, Pinterest, and Match2One.
When contacting you, we process your personal data to communicate with you and, for example, be able to answer your questions. If you participate in our competitions or if we share your posts on our social media/website, we process your personal data to:
carry out and manage your participation in competitions; and
share your posts on social media and your pictures on our website.
Our processing of personal data means that your personal data is shared with certain suppliers who process them outside the EU/EEA.
You have the following rights:
Right to complain to the local Data Protection Authority
Right to withdraw your consent
Right of access
Right to object
Right to erasure
Right to rectification
Right to restrict processing of personal data
Right to data portability
We want to be transparent when we process your personal data. You can read more details about our processing of personal data below. The policy is long, so please use our summary above and the table of contents below to click through to the part you want to read more about. It is important that you read and understand our privacy policy. Do not hesitate to contact us if you have any questions or want to exercise your rights.
Privacy Policy – More details
Click to read more about:
Data controller and how to contact us
Sharing of your personal data
Transfer of your personal data outside the EU/EEA
Detailed information about our processing and storage of your personal data
Your rights when we process your personal data
Balancing of interests
Data controller and how to contact us
Holdit AB ("Holdit"), with organization number 556456–9928, is responsible for the processing of your personal data. If you have any questions regarding our processing of your personal data or if you want to exercise any of your rights, you can contact us at our email address customerservice@holdit.com. Our address is Birger Svenssons väg 34B, 432 40 Varberg, Sweden.
Sharing of your personal data
We never sell your personal data. Primarily, your personal data is processed by us, but in some cases, we share your personal data. Read more details about this as well as in relation to each purpose and which personal data we share in the tables below. In summary, the following generally applies:
If you visit our website and give your consent, your personal data is processed by the analysis and marketing services we use, i.e., Google, Meta (Facebook and Instagram), TikTok, Pinterest, and/or Match2One. These recipients process personal data on our behalf as our processors but also process your personal data as independent controllers. These providers inform you separately about the processing of personal data they are responsible for.
If you make a purchase on our website, your personal data is processed by the payment service provider and carrier that you choose. These recipients are independent controllers for the processing of your personal data. Which payment service providers and carriers process your personal data is shown by the choice you make at checkout when purchasing. All providers are listed in the tables below.
To ensure that we have functioning IT systems and run our business efficiently, our IT providers will process your personal data. These IT providers process personal data on our behalf as processors.
If you want more information about how we share your personal data, please read further in the tables below or contact us.
Transfer of your personal data outside the EU/EEA
Some of our service providers and IT providers process personal data outside the EU/EEA. For us at Holdit, it is of utmost importance that all transfers outside the EU/EEA are carried out in accordance with GDPR.
If you visit our website, your personal data will be transferred outside the EU/EEA if you consent to Google, Meta (Facebook and Instagram), TikTok Pinterest, and Match2One processing your personal data.
If you are a member of our customer club, your personal data will be transferred outside the EU/EEA through our use of Yotpo.
When your personal data is transferred to countries outside the EU/EEA, this is done based on the European Commission's standard contractual clauses. We will transfer your personal data according to the standard contractual clauses (Article 46.2 (c) GDPR), Module 1 (controller-to-controller) and Module 2 (controller-to-processor), together with supplementary measures. You can find the standard contractual clauses here. In cases where we conclude that legislation or similar in a specific country outside the EU/EEA that we transfer your personal data to affects the effectiveness of the standard contractual clauses, we will take additional protective measures to ensure adequate protection for your personal data.
If you want to know more about what protective measures we implement when transferring your personal data, you are welcome to contact us.
Detailed information about our processing and storage of your personal data
In this detailed description, those interested can read more in detail about:
why we process your personal data;
the categories of personal data that we process;
the legal basis for processing your personal data; and
how long we store your personal data. If each processing involves that other than Holdit processes your personal data as well as what we mention above, we also state it below.
If you make a purchase on our website
In connection with making a purchase on our website, we process your personal data. For what purposes we process your personal data is shown in the tables below. We collect your personal data from you at checkout when you make your purchase on our website or in connection with contacting us.
Manage your purchase
Purpose
Receive and register your personal data to receive, register, and manage your order
Send order confirmation via email
Send delivery information via email and deliver your order
Share your personal data with payment service providers and carriers as described below
Personal data processed
Name
Contact details (address, email address, and phone number)
Order information, which products you have ordered
Payment information
Legal basis
Fulfillment of contract (GDPR Article 6.1 b) The processing is necessary for us to fulfill the contract regarding your purchase. If the personal data is not provided, you will not be able to make a purchase with us.
Storage period: The personal data related to your purchase will be actively processed by us for a few days to administer and manage your order so that you can receive the products you ordered. Thereafter, information about your purchase will be stored passively for 24 months if you are a member of our customer club and for 12 months if you are not, in order to handle any questions about your purchase, returns, right of withdrawal, and complaints smoothly and in accordance with applicable consumer regulations. You can read more about this below.
Recipients of your personal data: Our payment service providers will process your personal data in connection with the purchase. These providers are independent controllers for the processing of your personal data. You can read more in the privacy policies of the respective payment service providers.
We will share your name, address, and contact details with the carrier you choose at checkout to deliver your products. The carriers we use are independent controllers for the processing of your personal data. You can read more in the privacy policies of the respective carriers. We also share your personal data with our IT providers who process personal data on our behalf as our processors.
Handle any questions about your purchase, right of withdrawal, returns, and complaints in accordance with applicable consumer regulations and our contract
Purpose
Handle any questions about your purchase, right of withdrawal, returns, and complaints smoothly and in accordance with applicable consumer regulations and our contract with you
If you have questions about your purchase, want to exercise your right of withdrawal, complain about a product, or otherwise exercise any of your rights under applicable consumer law or our contract with you, we process your personal data to help you and comply with applicable law and the terms of our contract. For example, we may need to look up your order, your contact details, and your payment information for you to exercise your right of withdrawal or complain about a product. Read more about how we process your personal data to communicate with you if you contact us.
Personal data processed
Name
Contact details (address, email address, and phone number)
Order information, which products you have ordered
Information you choose to provide to us, such as details about a faulty product and information we have taken within a return case
Legal basis
Fulfillment of contract (GDPR Article 6.1 b)
The processing is necessary for us to fulfill the contract regarding your purchase. If the personal data is not provided, we will not be able to assist you with, for example, a complaint case.
Legal obligation (GDPR Article 6.1 c)
The processing is necessary for us to act in accordance with consumer law and thereby comply with a legal obligation that we have.
Balancing of interests (GDPR Article 6.1 f)
The processing is necessary for purposes related to our legitimate interest in being able to handle your questions, complaints, and other claims in an efficient and customer-friendly manner.
Storage period: We store your personal data for 24 months from your purchase to be able to answer questions about your purchase and to allow you to smoothly exercise your right to complain about your goods and exercise your right of withdrawal in accordance with applicable consumer purchase legislation.
If you contact us with a question and we initiate a case to handle your right of withdrawal, we process your personal data for 24 months. Read more about how long we otherwise process your personal data in our communication when you contact us.
Recipients of your personal data: Your personal data is shared with our IT providers who process this personal data on our behalf as our processors.
Send a request if you want to review your purchase
Purpose
Send requests to you to review the product you have purchased
Publish your review on our website if you have chosen to do so. You can choose whether to include your name
Personal data processed
Name
Contact details (address, email address, and phone number)
Order information, which products you have ordered
Information you choose to provide to us, such as details about a faulty product and information we have taken within a return case
Legal basis
Balancing of interests (GDPR Article 6.1 f)
The processing is necessary for purposes related to our legitimate interest in being able to contact you with a request to review our products to improve our products and our range.
Consent (GDPR Article 6.1 a)
We obtain your consent to publish your review on our website. You have the right to withdraw your consent at any time. Your withdrawal of consent does not affect the legality of processing before the consent is withdrawn.
Storage period: Your personal data is stored for 24 months after the purchase. However, we cease processing your personal data earlier if you object to our processing.
Recipients of your personal data: We use Trusted Shops to conduct surveys and manage your reviews. Trusted Shops will process your personal data on our behalf as our processor.
Comply with accounting regulations
Purpose
Comply with accounting legislation by recording, posting, and archiving your payments and other transactions that occur between us and you
Personal data processed
Payment history, transactions, and other material that constitutes accounting material
Legal basis
Legal obligation (GDPR Article 6.1 c)
The processing is necessary to comply with mandatory law, i.e., the Accounting Act.
Storage period: Personal data that is part of our accounting material is stored for seven to eight years to comply with the Accounting Act (end of the seventh fiscal year).
Recipients of your personal data: We share your personal data with our IT providers who process personal data on our behalf as our processors.
If you are a member of our customer club
You can choose to become a member of our customer club via our website. To be able to create your membership and fulfill what follows from it, we must process your personal data. If you do not provide your personal data to us, we will not be able to create or administer your membership. If you do not want to provide the information, you cannot be a member with us.
Based on your membership profile, we will also market our products to you in your digital channels. If you do not want marketing from us, you always have the right to opt out. Read more about your rights below.
We also process your personal data to show current and previous purchases, save your favorites, and remind you of products you left in the shopping cart.
We receive your personal data from you. In some cases, personal data is created within the framework of your membership, such as your points.
Manage your membership and My account
Purpose
Create your membership in our customer club
Create and enable your login to My Account
Communicate with you regarding your membership
Maintain accurate and up-to-date information for your membership
Personal Data Processed
Name
Contact details (email address and mobile number)
Your login details, i.e., email address and password
Settings of your profile and your choices
Legal Basis
Performance of a contract (GDPR Article 6.1b)
The processing is necessary for us to fulfill the agreement regarding your membership. If the personal data is not provided, you will not be able to become a member with us.
Storage Period: The data will be processed until you terminate your membership and for [specify] thereafter. If your membership has been inactive for 24 months, we will delete your membership and the associated information. By inactivity, we mean that you have not registered a membership purchase.
Recipients of Your Personal Data: To manage your membership and your member page, we use IT providers who process your personal data on our behalf as our data processors.
Manage your points and membership level, and display past and current purchases
Purpose
Enable you to register bonus-eligible purchases and use value vouchers, which includes identifying you as a member at the time of purchase
Calculate your points and inform you of your current points balance
Enable you to view and track your current and past purchases
Personal Data Processed
Name
Contact details (email address and mobile number)
Purchase and order history
Points and points balance
Purchase and order history
Legal Basis
Performance of a contract (GDPR Article 6.1b)
The processing is necessary for us to manage your points and membership level in accordance with our membership terms and thereby fulfill our agreement with you. If the personal data is not provided, we will not be able to calculate your points.
Performance of a contract (GDPR Article 6.1b)
The processing is necessary to administer your member pages in accordance with the membership terms and thereby fulfill our agreement with you.
Storage Period: Your earned points and membership level are stored for 12 months, or until your membership is terminated. To display current and past purchases, your personal data is stored for 24 months after the purchase. However, we will cease processing your personal data earlier if you object to our processing.
Recipients of Your Personal Data: To manage your points and membership level and display current and past purchases, we use IT providers who process your personal data on our behalf as our data processors.
Send newsletters and other marketing to you as a member of our customer club
Purpose
Manage and send marketing with offers, benefits, discounts, and information in newsletters via email and SMS if you have joined our customer club. You can opt out of marketing from us at any time.
Send personalized product recommendations and communication, so you receive offers and information about goods and services you are interested in.
Develop and improve our newsletters and marketing by analyzing how you interact with our newsletters.
Personal Data Processed
Name
Contact details (email address and mobile number)
For personalized communication, the following data is also processed:
Information about your membership level and points
Purchase and order history
Your birthday, if you choose to provide it
Information about how you interact with our newsletters, such as what you click on
IP address
Email address
Legal Basis
Legitimate interest (GDPR Article 6.1f)
The processing is necessary for purposes related to our legitimate interest in being able to provide you with newsletters and personalized offers.
Legitimate interest (GDPR Article 6.1f)
The processing is necessary for purposes related to our legitimate interest in developing and improving our newsletters and marketing.
Storage Period: The data will be processed until you terminate your membership. You can opt out of marketing from us (in whole or in part) at any time, and we will then stop processing your personal data for marketing purposes. If you opt out of our marketing, your personal data will be stored in our opt-out register indefinitely.
Recipients of Your Personal Data: For sending and analyzing our newsletters and other marketing, we use IT providers who process your personal data on our behalf as our data processors.
Remind you as a member of our customer club about products you have left in your shopping cart
Purpose
Send reminders to you as a member via email if you have left products in the shopping cart on our website without completing the purchase
Personal Data Processed
Email address
Information about products you have left in the shopping cart
Legal Basis
Legitimate interest (GDPR Article 6.1f)
The processing is necessary for purposes related to our legitimate interest in being able to remind you about products you have left in the shopping cart when this is done for you as a member of our customer club and you have been given the opportunity to object to direct marketing.
Storage Period: We will send a maximum of three reminders to you. The personal data will be processed by us for up to 90 days after you left products in the shopping cart. You can opt out of marketing from us at any time, and we will then stop processing your personal data for marketing purposes. If you opt out of our marketing, your personal data will be stored in our opt-out register indefinitely.
Recipients of Your Personal Data: We share your personal data with our IT providers who process your personal data on our behalf as our data processors.
If You Save Your Favorites
We process your personal data to offer you a feature to save your favorites. We receive your personal data from you when you mark products as favorites.
Save your favorites
Purpose
Offer you a feature to save your favorites
Personal Data Processed
Information about your favorite markings linked to your account
Legal Basis
Legitimate interest (GDPR Article 6.1f)
The processing is necessary for purposes related to our legitimate interest in being able to offer you a feature to save your favorites.
Storage Period: Your favorite markings are stored for 90 days or until you remove the favorite markings yourself.
Recipients of Your Personal Data: To offer favorite markings, we use IT providers who process your personal data on our behalf as our data processors.
If you have chosen to subscribe to our newsletter
We process your personal data if you have chosen to subscribe to our newsletters. We receive your personal data from you when you choose to enter your email address to subscribe to our newsletters.
Send newsletters and analyze your interaction with them
Purpose
Send newsletters to you via email
Develop and improve our newsletters and marketing by analyzing how you interact with our newsletters
Personal Data Processed
Email address
Information on how you interact with our newsletters, such as information on what you click on
IP address
Legal Basis
Consent (GDPR Article 6.1 a): We obtain your consent to send newsletters to you. You can withdraw your consent at any time.
Legitimate Interest (GDPR Article 6.1 f): The processing is justified by our legitimate interest in developing and improving our newsletters and marketing.
Storage Period: You will continue to receive newsletters until you withdraw your consent or unsubscribe from our mailings. You can withdraw your consent and unsubscribe from our newsletter at any time. If you withdraw your consent or unsubscribe from our mailings, your personal data will be stored in our unsubscribe register until further notice.
Recipients of Your Personal Data: Your personal data is shared with our IT providers who process this data on our behalf as our data processors.
When you visit our website
We analyze how our website is used and show you relevant offers on other sites and social media you visit based on such analysis. We explain this in detail in the tables below.
To protect your privacy, we and our providers have taken measures to avoid identifying you as a user of our website.
Personal data is collected from your device (such as mobile, computer, or tablet) when you visit our website, if you have chosen to consent to it. Our providers Google, Meta, TikTok, and Pinterest also use information they have previously collected to conduct analysis and show you interesting offers from us.
To collect personal data for analysis and marketing as described below, we use cookies and/or similar technologies. If you want to know more about this, please feel free to contact us.
Analyze how our website is used
Purpose
Analyze how you use our website using cookies. We do this to improve the functionality of the website, to tailor the website to suit our visitors, and to draw conclusions about our visitors.
To do this, we use an analytics service from Google Analytics, which involves using a random ID to distinguish your device from other visitors and to confirm patterns in how our website is used. We also use Google's service to generate reports from the analyses performed. We are only interested in how visitors interact with us on an overall level. At Holdit, we do not know who you are and take no steps to find out.
Personal Data Processed
Information on how you use the website, such as what you click on
The region in the country from which you use our website
How many times you have visited the website, which provides us with data to count the total number of visitors to the website
Your device/browser, such as your screen resolution
Other information that these providers have about you, such as information on which website you found us from
Legal Basis
Consent (GDPR Article 6.1 a): For the personal data we process to analyze your use of our website, we obtain your consent when you visit our website.
You have the right to withdraw your consent at any time. Your withdrawal of consent does not affect the legality of processing before the consent is withdrawn.
You can avoid Google Analytics by, for example, downloading and installing this browser program.
Storage Period: The personal data will be used by us for 24 months after your visit to our website.
Recipients of Your Personal Data: Your personal data is collected via a pixel on our website by Google, which provides the analytics service we use. Google will continue to process your personal data as an independent data controller. You can read more about Google's data processing and how long Google stores your personal data in their privacy policy, which you can find here.
Analyze from which partner you found our website
Purpose
Analyze where you found us using a pixel. We do this to be able to pay the correct compensation to our partners based on the success of our marketing.
To do this, we use an analytics service from Awin (affiliate).
Personuppgifter som behandlas
Information om från vilken samarbetspartner du hittade till vår hemsida
Legal Basis
Consent (GDPR Article 6.1 a): For the personal data we process to analyze your use of our website, we obtain your consent when you visit our website. You have the right to withdraw your consent at any time. Your withdrawal of consent does not affect the legality of processing before the consent is withdrawn.
Storage Period: The personal data will be used by us for 24 months after your visit to our website to maintain our partner agreements.
Recipients of Your Personal Data: Your personal data is collected via a pixel on our website by Awin, which provides the analytics service we use. You can read more about Awin's data processing and how long Awin stores your personal data in their privacy policy, which you can find here.
Show interesting offers from us on other sites you visit
Purpose
Market our products by showing offers and new products we believe are interesting to you. We display marketing tailored specifically to you on other websites and social media you visit.
We can show offers using marketing services from Google, Meta (Facebook and Instagram), TikTok, Pinterest, and/or Snapchat. We do this based on the analysis of our website, through cookies or similar technology, and information these parties have about you from before. We also use Google's Looker Studio service to generate reports on our marketing. We tailor the marketing to suit you based on information the marketing services have about you from before and based on your previous browsing history with us. This means that profiling of your browsing history takes place.
Personal Data Processed
Encrypted IP address that we at Holdit cannot link to you personally
The region in the country from which you use our website
Information on how you interact with our website or ads. For example, information on which pages you visited after clicking on our ad, as well as analysis of how and when you use our website, such as if you add something to the cart, make a purchase, or search for something
Information that the marketing services have about you from before, such as from which website you found us
Legal Basis
Consent (GDPR Article 6.1):
For the personal data we process for marketing purposes, we obtain your consent when you visit our website.
You have the right to withdraw your consent at any time. Your withdrawal of consent does not affect the legality of processing before the consent is withdrawn. Here you can make choices about the marketing you see from Google. Here you can find more information about your choices on Instagram, and here on Facebook under the heading ad settings, you can choose which marketing you want to see on Facebook.
Storage Period: Your personal data will be processed, and you will see marketing from us for 24 months after your visit to our website.
Recipients of Your Personal Data: Your personal data is shared with the marketing services we use. The marketing services we use will continue to process your personal data as independent data controllers. You can read more about the marketing services' data processing and how long Google, Meta, TikTok, Pinterest, and Snapchat store your personal data in their respective privacy policies. Click on the name to read more.
Profiling: Your personal data is used for so-called profiling, which the marketing services use to show you the offers that they and we believe suit you best and to provide tailored marketing. Profiling is done because otherwise, we would not be able to show relevant offers and marketing specifically for you; otherwise, you would see offers that are not relevant to you. You have the right to object to profiling. You can read more about your right to object below, where your rights are explained in detail.
When contacting you
When you contact us, for example via our customer service or social media, or if we communicate with you regarding your purchase, we will process your personal data as described in the tables below. We receive your personal data from you when you contact us.
If you use social media, the social media platform you use (for example, Instagram) will also process your personal data, and we therefore recommend that you read our information below together with the information you find on the social media platform.
When contacting you
Purpose
Communicate with you if you contact us, for example through our customer service or on our social media pages
Communicate with you regarding your purchase if needed, e.g., if the product you ordered is out of stock
Personal data processed
Name
The contact details you use, such as email address, phone number, and/or address
Other information you provide in connection with our contact, e.g., order number
Information about your order and the product you have purchased
If you contact us through social media (e.g., our Facebook), we also process information from your profile (username and the picture you have chosen for your account)
Legal basis
Legitimate Interest (GDPR Article 6.1 f): The processing is necessary for purposes related to our legitimate interest in being able to communicate with you via the channel you choose to contact us on.
Legal Obligation (GDPR Article 6.1 c): The processing is necessary for us to act in accordance with GDPR and thereby comply with a legal obligation we have.
Storage period: We store your personal data to communicate with you regarding your purchase for 24 months after your purchase. We store personal data that appears in communication in our customer service cases for 24 months from the conclusion of our contact regarding the case.
On social media, we delete your comments and our communication after 24 months. You can remove your own comments/communication yourself. Material that may be perceived as offensive is removed continuously. This includes, for example, unpleasant comments, inappropriate language, or attacks on individuals.
Recipients of your personal data: Within the framework of a customer service case, your personal data is shared with our IT provider who processes this personal data on our behalf as our data processor.
If you contact us via social media, the social media platform also receives your personal data.
If you participate in competitions or if we share your posts on our social media/website
If you participate in a competition with us, we will process your personal data. We obtain your personal data from you through your participation in the competition and from your social media.
Conduct and manage your participation in competitions
Purpose
Conduct and manage your participation in competitions
Contact you to inform you if you have won a competition
Personal data processed
Name
Username from the social media you participate from
Your competition entry and other information you provide to us when participating in the competition
Legal basis
Legitimate interest (GDPR Article 6.1 f)
The processing is necessary for purposes related to our legitimate interest in being able to conduct and manage your participation in our competitions.
Retention period: We delete the personal data no later than 24 months after the competition has ended.
Recipients of your personal data: If the competition is conducted on one of our social channels, the relevant social media platform, such as Instagram, will have access to your personal data.
Share your posts on social media and your photos on our website
Purpose
Share your posts on social media where you have tagged us or used one of our hashtags if you have given your consent to it
Send a request to you asking if we may use your content in our marketing on our website and social media
Share your content on our website and social media if you consent to it.
Personal data processed
Name
Username on platforms such as Instagram
Your content on social media where you have tagged us, such as posts from Instagram
Name
Your email address
Username on platforms such as Instagram
Your content on social media, such as your photos from Instagram
Legal basis
Legitimate interest (GDPR Article 6.1 f)
The processing is necessary for purposes related to our legitimate interest in being able to share your posts on social media when you have chosen to tag us or used one of our hashtags if you have given your consent to it.
Consent (GDPR Article 6.1 a)
For the personal data we process for marketing purposes and to share your content on our website and social media, we obtain your consent. You have the right to withdraw your consent at any time. Your withdrawal of consent does not affect the legality of processing before the consent is withdrawn.
Retention period: We keep the personal data included in the post you have chosen to publish and that we have shared, and therefore process as described above, on our website or on our social media account indefinitely. We continuously clean up the content when it is no longer relevant (which varies from post to post) or when you contact us and ask us to remove the post or your personal data.
Recipients of your personal data: Your personal data is shared with our IT providers who process this personal data on our behalf as our data processors. If we share your post on our social channels, the relevant social media platform, such as Instagram, will have access to your personal data.
If you have asked us to stop sending marketing to you
Below is a description of how we process your personal data if you have unsubscribed from our marketing. We have received your data from you.
Comply with marketing laws
Purpose
If you have notified us that you do not wish to receive marketing or if we stop sending newsletters, we will store your email address in an "unsubscribe register" to ensure that we do not market to you.
This is not personal data that we actively process; we do not look at your email address and do not use it for anything other than ensuring that you do not receive marketing from us.
Personal data processed
Email address
Information that you no longer wish to receive marketing from us
Legal basis
Legal obligation (GDPR Article 6.1 c)
The processing is necessary to fulfill our obligation under marketing laws to ensure that you do not receive mailings that you have requested not to receive.
Retention period: Your email address will remain in our "unsubscribe register" until you ask us to remove your email address from there.
Recipients of your personal data: Your personal data is shared with our IT providers who process this personal data on our behalf as our data processors.
Your rights when we process your personal data
In accordance with GDPR, you have certain rights in relation to our processing of your personal data. If you have any questions about these rights or wish to exercise any of your rights, you are welcome to contact us using the contact details provided above. More detailed information about your rights can be found below.
Right to lodge a complaint with a supervisory authority (Article 77 of GDPR)
You have the right to lodge a complaint with a competent supervisory authority if you believe that the processing of your personal data violates the GDPR.
– In detail. Your right to lodge a complaint applies without prejudice to any other administrative or judicial remedy. Such a complaint is preferably lodged with the authority in the Member State where you have your habitual residence, where you work, or where an alleged infringement of applicable data protection laws and regulations has occurred.
The supervisory authority is obliged to inform you about the progress and the outcome of the complaint, including the possibility of a judicial remedy.
For a list of local supervisory authorities, please refer to the end of this document.
Right to withdraw consent (Article 7.3 of GDPR)
You have the right to withdraw your consent at any time by contacting us.
– In detail. Your withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
Right of access (Article 15 of GDPR)
You have the right to obtain confirmation as to whether or not we are processing your personal data. You can submit a request by contacting us. If we are processing your personal data, you also have the right to obtain a copy of the personal data we process and information about the processing.
In detail. The information we provide you access to includes:
the purposes of the processing,
the categories of personal data concerned,
the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations,
where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period,
the existence of the right to request from us rectification or erasure of personal data or restriction of processing of personal data concerning you or to object to such processing,
the right to lodge a complaint with a supervisory authority,
if we do not collect the data from you, any available information as to their source,
the existence of automated decision-making, including profiling, referred to in Articles 22(1) and 22(4) of GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for you; and
where personal data are transferred to a third country or to an international organization, you have the right to be informed of the appropriate safeguards pursuant to Article 46 of GDPR relating to the transfer.
You have the right to obtain a copy of the personal data undergoing processing. For any further copies requested by you, we may charge a reasonable fee based on administrative costs. If you have made the request by electronic means, the information will be provided in a commonly used electronic form, unless you request otherwise.
Your right to obtain copies as described above shall not adversely affect the rights and freedoms of others.
A request can be made by contacting us using our contact details.
Right to object (Article 21 of GDPR)
In the cases specified below, you have the right to object at any time to the processing of personal data concerning you.
– In detail. Your right to object applies as follows:
You have the right to object at any time, on grounds relating to your particular situation, to the processing of your personal data which is based on Article 6.1 f of GDPR, which includes profiling based on this provision. If you object, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights, and freedoms or for the establishment, exercise, or defense of legal claims.
If your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data for such marketing, which includes profiling to the extent that it is related to such direct marketing. If you object to processing for direct marketing purposes, you have the unconditional right to have the processing of your personal data for such purposes cease.
Right to erasure ("right to be forgotten") (Article 17 of GDPR)
In the cases specified below, you have the right to have your personal data erased by us without undue delay.
– In detail. We are obliged to erase personal data without undue delay if any of the following applies:
the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw your consent on which the processing is based, and there is no other legal ground for the processing;
you object to the processing pursuant to Article 21.1 of GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Article 21.2 of GDPR;
the personal data have been unlawfully processed;
the personal data must be erased to comply with a legal obligation in Union or Member State law to which we are subject.
If we have made the personal data public and are obliged to erase the personal data as described above, we shall, taking account of available technology and the cost of implementation, take reasonable steps, including technical measures, to inform other controllers processing the personal data that you have requested the erasure of any links to, or copies or replications of, those personal data.
We will inform each recipient to whom the personal data have been disclosed of any erasure carried out as described above, unless this proves impossible or involves disproportionate effort. If you would like information about these recipients, you are welcome to contact us.
Please note that our obligation to erase as described above does not apply to the extent that processing is necessary for the following reasons:
for exercising the right of freedom of expression and information;
for compliance with a legal obligation which requires processing according to Union or Member State law to which we are subject; or
for the establishment, exercise, or defense of legal claims.
Right to rectification (Article 16 of GDPR)
You have the right to have inaccurate personal data concerning you rectified without undue delay.
– In detail. Taking into account the purposes of our processing of your personal data, you also have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
We will inform each recipient to whom the personal data have been disclosed of any rectification carried out, unless this proves impossible or involves disproportionate effort. If you would like information about these recipients, you are welcome to contact us.
Right to restriction of processing (Article 18 of GDPR)
In the cases specified below, you have the right to request that the processing of your personal data be restricted.
In detail. Your right applies if:
you contest the accuracy of the data (but only for a period enabling us to verify the accuracy of the data),
you have objected to processing pursuant to Article 21.1 of GDPR pending the verification of whether the legitimate grounds of the controller override those of the data subject,
the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead, or
you need the personal data for the establishment, exercise, or defense of legal claims even though we no longer need the personal data for the purposes of the processing.
If the processing has been restricted as described above, such personal data, with the exception of storage, may only be processed with your consent or for the establishment, exercise, or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State. We will inform you before the restriction of processing is lifted.
We will inform each recipient to whom the personal data have been disclosed of any restriction of processing carried out as described above, unless this proves impossible or involves disproportionate effort. If you would like information about these recipients, you are welcome to contact us.
Right to data portability (Article 20 of GDPR)
In the cases specified below, you have the right to receive your personal data (which you have provided to us) in a structured, commonly used, and machine-readable format from us. You also have the right to have your personal data transferred to another controller where technically feasible ("data portability").
In detail: The right to data portability applies to personal data that you have provided to us in a structured, commonly used, and machine-readable format if:
the processing is based on the legal basis of consent or the performance of a contract, and
the processing is carried out by automated means.
Your right to data portability does not affect your right under Article 17 of GDPR (right to erasure).
Your right to data portability must not adversely affect the rights and freedoms of others.
Supervisory Authorities
The list below shows the supervisory authorities for each respective market:
Legitimate interest
As stated in the tables above, we process some of your personal data based on a legitimate interest as the legal basis for the processing. The legitimate interest assessment means that we have determined that our legitimate interest in carrying out the processing outweighs your interest and fundamental rights not to have your personal data processed. Our legitimate interest is specified in the tables above.
If you would like to know more about how we have made these assessments, you are welcome to contact us.
This privacy policy was established by Holdit on 2023-01-16.