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Privacy Notice

PRIVACY POLICY

TLC Trading GmbH, Grindelstrasse 12, CH-8303 Bassersdorf is operator of the websites Teleshop.ch, Slimshop.ch Genialo.ch and the services offered on them and therefore responsible for the collection, processing and use of your personal data and the compatibility of data processing with the applicable data protection law.
Your trust is important to us, which is why we take the subject of data protection seriously and pay attention to appropriate security. Of course, we observe the legal provisions of the Federal Data Protection Act (DSG), the Ordinance to the Federal Data Protection Act (VDSG), the Telecommunications Act (FMG) and other applicable data protection provisions of Swiss or EU law, in particular the Basic Data Protection Ordinance (DSGVO).
In order for you to know what personal data we collect from you and for what purposes we use it, please take note of the following information.

1. visit our website
When you visit our website, our servers temporarily store each access in a log file. As with any connection to a web server, the following technical data is recorded without your intervention and stored by us after 2 months at the latest until it is deleted:
the IP address of the requesting computer,
the name of the owner of the IP address range (usually your Internet access provider),
the date and time of access,
the website from which the access was made (referrer URL), if applicable with the search term used,
the name and URL of the retrieved file,
the status code (e.g. error message),
the operating system of your computer,
the browser you are using (type, version and language),
the transmission protocol used (e.g. HTTP/1.1) and
if necessary, your user name from a registration/authentication
These data are collected and processed for the purpose of enabling the use of our website (connection establishment), to permanently guarantee system security and stability and to enable the optimisation of our Internet offer as well as for internal statistical purposes. This is our legitimate interest in data processing within the meaning of Art. 6 para. 1 lit. f DSGVO.

2. opening of a customer account
To place orders in the online shop, you can order as a guest or open a customer account. When registering for a customer account, we collect the following data:
First and last name
Postal address
Date of birth
E-mail address
Password
The data is collected for the purpose of providing the customer with direct access to his basic data stored by us. The customer can view his completed and open orders or manage or change his personal data. The legal basis for the processing of the data for this purpose is the consent given by you pursuant to Art. 6 para. 1 lit. a EU DSGVO.

3. purchase in the onlineshop
If you would like to place orders in our online shop, we need the following data to process the contract:
First and last name
Billing address (and if different delivery address)
Payment details (depending on the chosen payment method)
Login data, i.e. e-mail address and password (for registered customers)
Unless otherwise stated in this privacy policy or unless you have given your separate consent, we will only use the above data to process the contract, in particular to process your orders, deliver the products ordered and ensure correct payment. The legal basis of data processing for this purpose is the fulfilment of a contract in accordance with Art. 6 para. 1 letter b EU DSGVO.

4. passing on the data to third parties
We will only pass on your personal data if you have expressly consented, if there is a legal obligation to do so or if this is necessary for the enforcement of our rights, in particular for the enforcement of claims arising from the contractual relationship.  Furthermore, we pass on your data to third parties as far as this is necessary in the context of the use of the website and the contract processing (also outside the website), namely the processing of your bookings. This includes the respective transport service provider who was entrusted with the dispatch of ordered goods. A service provider to whom the personal data collected via the website is passed on or to whom access is or may be granted is our web host Nine Internet Solutions AG Albisriederstrasse 243a, CH-8047 Zurich (Teleshop.ch) and Profihost AG Expo Plaza 1, 30539 DE-Hannover (Slimshop.ch and Genialo.ch). The website is hosted on servers in[CH and DE]. The data is passed on for the purpose of providing and maintaining the functionalities of our website. This is our legitimate interest within the meaning of Art. 6 para. 1 lit. f EU DSGVO. If we make advance payments, e.g. in the case of a purchase on account, we may obtain credit information from a credit agency on the basis of mathematical-statistical procedures in order to safeguard our legitimate interests. For this purpose, we transmit the personal data required for a credit assessment to the credit agency Intrum AG Eschenstrasse 12, CH-8603 Schwerzenbach and use the information received about the statistical probability of non-payment for a balanced decision on the establishment, implementation or termination of the contractual relationship. The credit information can contain probability values (score values), which were calculated on the basis of scientifically recognised mathematical-statistical methods and in the calculation of which address data, among other things, are included. Your interests worthy of protection are taken into account in accordance with the legal provisions. For the purposes described above, we have a legitimate interest in data processing within the meaning of Art. 6 para. 1 lit. f EU DSGVO. Finally, we forward your credit card information to your credit card issuer and the credit card acquirer Datatrans AG Kreuzbühlstrasse 26, CH-8008 Zurich. If you decide to pay by credit card, you will be asked to enter all necessary information. The legal basis for the transfer of the data is the fulfilment of a contract in accordance with Art. 6 para. 1 lit. b EU-DSGVO. Concerning the processing of your credit card information by these third parties, we ask you to also read the General Terms and Conditions and the data protection declaration of your credit card issuer.

5. transmission of data abroad
We are entitled to transfer your personal data to third parties (commissioned service providers) abroad for the purpose of the data processing described in this data protection declaration. These are obliged to the same extent as we ourselves to data protection. If the level of data protection in a country does not correspond to that in Switzerland or Europe, we contractually ensure that the protection of your personal data corresponds at all times to that in Switzerland or the EU.

6. cookies
Cookies help in many ways to make your visit to our website easier, more pleasant and more meaningful. Cookies are information files that your web browser automatically stores on your computer's hard drive when you visit our website. For example, we use cookies to offer you the shopping cart function over several pages and to temporarily save your entries when filling out a form on the website so that you do not have to repeat the entry when calling up another subpage. Cookies may also be used to identify you as a registered user after registering on the website, without you having to log in again when calling another subpage. Most Internet browsers automatically accept cookies. However, you can configure your browser so that no cookies are stored on your computer or a message appears whenever you receive a new cookie. On the following pages you will find explanations on how you can configure the processing of cookies with the most common browsers:
Microsoft's Windows Internet Explorer
https://support.microsoft.com/de-de/help/17442/windows-internet-explorer-delete-manage-cookies
Microsoft's Windows Internet Explorer Mobile
https://support.microsoft.com/en-us/help/10635/windows-phone-change-privacy-and-other-browser-settings
Mozilla Firefox
https://support.mozilla.org/de/kb/cookies-erlauben-und-ablehnen
Google Chrome for Desktop
https://support.google.com/chrome/answer/95647?hl=en
Google Chrome for Mobile
https://support.google.com/chrome/answer/2392709?hl=en&co=GENIE.Platform%3DAndroid&oco=1
Apple Safari for Desktop
https://support.apple.com/kb/PH17191?locale=en_US&viewlocale=en_EN
Apple Safari for Mobile
https://support.apple.com/de-de/HT201265
Disabling cookies may prevent you from using all the features of our website.

7. tracking tools
a.    General information
We use the web analysis service of Google Analytics for the purpose of demand-oriented design and continuous optimization of our website. In this context, pseudonymous user profiles are created and small text files stored on your computer ("cookies") are used. The information generated by the cookie about your use of this website is transmitted to the servers of the providers of these services, stored there and processed for us. In addition to the data listed under point 1, we may receive the following information:
Navigation path followed by a visitor to the Site,
Order value
Duration of stay on the website or subpage,
the subpage on which the website is left,
the country, region or city from which it is accessed,
terminal (type, version, color depth, resolution, width and height of the browser window) and
Returning or new visitor.
The information is used to evaluate the use of the website, to compile reports on the website activities and to provide further services associated with the use of the website and the Internet for purposes of market research and demand-oriented design of this website. This information may also be transferred to third parties if this is required by law or if third parties process this data on behalf of the company.

b.    Google Analytics
Google Analytics is provided by Google Inc, a company of the holding company Alphabet Inc, based in the USA. Prior to the transmission of the data to the Provider, the IP address will be reduced by activating IP anonymization ("anonymizeIP") on this website within the Member States of the European Union or in other countries party to the Agreement on the European Economic Area. The anonymous IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. In such cases, we provide contractual guarantees to ensure that Google Inc. maintains an adequate level of privacy. According to Google Inc., under no circumstances will the IP address be linked to other data relating to the user. Further information about the web analysis service used can be found on the Google Analytics website. Instructions on how to prevent your data from being processed by the web analysis service can be found at http://tools.google.com/dlpage/gaoptout?hl=en.

c.    Econda Analytics
For the demand-oriented design and optimisation of this website, anonymised data are collected and stored by solutions and technologies of econda GmbH Zimmerstr. 6 DE-76137 Karlsruhe and user profiles are created from these data using pseudonyms. For this purpose, cookies may be used that enable the recognition of an Internet browser. However, user profiles are not merged with data about the bearer of the pseudonym without the express consent of the visitor. In particular, IP addresses are made unrecognizable immediately after receipt, which makes it impossible to assign user profiles to IP addresses. Visitors to this website may object to the collection and storage of data here at any time in the future. The objection applies only to the device and the web browser on which it was set, please repeat the procedure on all devices if necessary. If you delete the opt-out cookie, requests are sent to conda again.

8. retargeting
For the use of retargeting and banner advertising we use services of third parties which set cookies on our site. These are the following providers:
Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2 Ireland https://www.facebook.com/about/privacy
Doubleclick by Google, Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; https://www.google.de/intl/de/policies/technologies/ads/

9. conversion measurement with the visitor action pixel of Facebook
With your consent, we use the "visitor action pixel" of Facebook Inc, 1601 S. California Ave, Palo Alto, CA 94304, USA ("Facebook") within our Internet presence. It allows us to track the actions of users who have seen or clicked on a Facebook ad. This enables us to measure the effectiveness of Facebook ads for statistical and market research purposes. The data collected in this way is anonymous to us, i.e. we do not see the personal data of individual users. However, this data is stored and processed by Facebook, about which we inform you according to our level of knowledge. Facebook may link this information to your Facebook account and also use it for its own promotional purposes, in accordance with Facebook's Data Usage Policy https://www.facebook.com/about/privacy/. You can allow Facebook and its partners to serve ads on and off Facebook. A cookie may also be stored on your computer for these purposes.

10. Newsletter Marketing
Customers have the opportunity to subscribe to our electronic newsletter. If you no longer wish to receive newsletters, you can simply unsubscribe by pressing the "Unsubscribe" button. We use the third party provider CleverReach GmbH & Co. KG mill road 43 DE-26180 Rastede. The company provides us with evaluation tools with which we can measure the success of the sent newsletters.
The information generated by the cookie is transmitted to the servers of the provider of these services, stored there and processed for us. Among other things, the following information is recorded: Opening and clicking behaviour.

11. note on data transmission to the USA
For reasons of completeness, we would like to point out to users residing or domiciled in Switzerland that monitoring measures are in place in the USA by US authorities, which generally allow the storage of all personal data of all persons whose data was transmitted from Switzerland to the USA. This is done without differentiation, restriction or exception based on the objective pursued and without an objective criterion which makes it possible to restrict the access of the US authorities to the data and their subsequent use to very specific, strictly limited purposes which are capable of justifying the intervention associated with access to these data and their use. Furthermore, we would like to point out that there are no legal remedies available in the USA for the data subjects from Switzerland that would allow them to access the data concerning them and to obtain their correction or deletion, or that there is no effective legal protection against general access rights of US authorities. We explicitly point out this legal and factual situation to the person concerned in order to make an appropriately informed decision to consent to the use of his data. Users residing in an EU Member State are advised that the US does not have an adequate level of data protection from the point of view of the European Union, partly because of the issues mentioned in this section. If we have explained in this privacy policy that recipients of data (such as Google) are based in the USA, we will ensure that your data is protected by our partners at an appropriate level, either by contractual arrangements with these companies or by ensuring that these companies are certified under the EU or Swiss-US privacy label.

12. right of access, rectification, cancellation and restriction of processing; right to data transferability
You have the right to request information about the personal data that we store about you. In addition, you have the right to correct incorrect data and to have your personal data deleted, insofar as this does not conflict with any legal obligation to retain data or an event of authorisation which allows us to process the data. You also have the right to reclaim from us the data that you have provided to us (right of data portability). Upon request, we will also pass the data on to a third party of your choice. You have the right to receive the data in a common file format. You can contact us for the above-mentioned purposes via the e-mail address info@tlc-trading.ch We may, at our sole discretion, require proof of identity to process your applications.

13 Data security
We use appropriate technical and organizational security measures to protect your personal data stored with us against manipulation, partial or complete loss and against unauthorized access by third parties. Our security measures are continuously improved in line with technological developments. You should always treat your access data confidentially and close the browser window when you have finished communicating with us, especially when you share your computer with others. We also take internal data protection very seriously. Our employees and the service companies commissioned by us have been obliged by us to maintain confidentiality and to comply with data protection regulations.

14. storage of data
We store personal data only as long as it is necessary to use the above-mentioned tracking and analysis services and further processing within the scope of our legitimate interest. We keep contractual data for a longer period of time, as this is prescribed by legal storage obligations. Storage obligations, which oblige us to keep data, result from accounting regulations and tax law regulations. According to these regulations, business communications, contracts concluded and accounting records must be kept for up to 10 years. If we no longer need this data to perform the services for you, the data will be blocked. This means that the data may then only be used for accounting and tax purposes.

15. right of appeal to a data protection supervisory authority
You have the right to complain at any time to a data protection supervisory authority.

Status: May 2018

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