Privacy policy

1. Contact

2. Collecting Personal Information

3. Sharing Personal Information

4. Behavioural Advertising

5. Using Personal Information

6. No Sale of Personal Information

7. Your Rights

8. Cookies

9. Changes

10. Complaints

1. contact

If you have any questions about this Privacy Policy, about how we handle your personal data, or if you wish to exercise your data protection rights, please contact us at:

Systoms GmbH
E-mail: the-fashionformula@systoms.de
Managing Director: Leonardo Dilßner

You also have the right to lodge a complaint with a supervisory authority responsible for data protection. In Germany, this is typically the data protection authority of your place of residence or the supervisory authority of our registered office.

2. collecting personal information

When you visit our website, we collect certain information about your device, interaction with the site, and information necessary to process your purchases. We also collect additional information if you contact us for support.

I - Device information

- Purpose of processing: To display the website correctly, ensure stability and security, and optimize our services.

- Legal basis: Art. 6 (1) f GDPR (legitimate interest).

- Data collected: Browser type, IP address, time zone, cookie information, which pages or products you view, search terms, and how you interact with the site.

- Recipients: Hosting provider and our e-commerce provider Shopify International Ltd., 2nd Floor, Victoria Buildings, 1–2 Haddington Road, Dublin 4, D04 XN32, Ireland. Data may be transferred to Canada or the USA under the EU standard contractual clauses.

II - Order information

- Purpose of processing: To fulfil our contract with you, process your payment, send invoices or confirmations, and provide customer support.

- Legal basis: Art. 6 (1) b GDPR (contract fulfilment) and Art. 6 (1) c GDPR (legal obligation).

- Data collected: Name, billing address, payment details (credit card, bank), e-mail address, and purchased product details.

Recipients: Shopify (as above), payment providers (e.g. Stripe, PayPal).

III - Customer support information

- Purpose of processing: To respond to your inquiries or support requests.

- Legal basis: Art. 6 (1) f GDPR (legitimate interest).

- Data collected: E-mail address, name, message content.

Minors

Our website is not intended for individuals under the age of 16. We do not knowingly collect personal data from children. If you are a parent or guardian and believe your child has provided us with data, please contact us to request deletion.

3. sharing personal information

We only share your personal data with third parties if this is necessary for fulfilling our contractual obligations, to operate this website, or if we are legally obliged to do so.

I. Service Providers
We use the e-commerce platform Shopify International Ltd., 2nd Floor, Victoria Buildings, 1–2 Haddington Road, Dublin 4, D04 XN32, Ireland to operate our online store. Data may also be processed by Shopify Inc., 151 O’Connor Street, Ground Floor, Ottawa, ON K2P 2L8, Canada or Shopify Inc., 150 Elgin Street, Ottawa, Ontario, Canada.
Shopify’s privacy policy can be found here: https://www.shopify.com/legal/privacy.
Data transfers to Canada and the USA are based on the EU Standard Contractual Clauses (Art. 46 GDPR).

II. Payment Providers
To process payments, we use external payment services such as Stripe Payments Europe Ltd. and/or PayPal (Europe) S.à r.l. et Cie, S.C.A.. The data required for payment processing (e.g. name, address, payment details) are transmitted directly to the payment provider and are processed there under their own responsibility.

III. Marketing and Analytics
If you have consented, we use analytics and marketing services such as Meta (Facebook) Pixel, Google Analytics, or newsletter tools (e.g. Klaviyo, Mailchimp). These services may involve data transfers to the USA under the EU Standard Contractual Clauses.

IV. Legal Obligations
We may also share your personal data if required by law or to comply with binding requests from public authorities (e.g. tax authorities, courts).

4. behavioural advertising

With your consent, we use analytics and marketing tools to understand how visitors use our website and to display personalized advertisements and email campaigns on other platforms (e.g. Facebook, Instagram, Google).

Legal basis: Art. 6 (1) a GDPR (your consent).
You can withdraw your consent at any time by changing your cookie settings or by using the opt-out links below.

Tools used:

Google Analytics – to analyze website usage.
Privacy Policy: https://policies.google.com/privacy
Opt-out: https://tools.google.com/dlpage/gaoptout

Meta (Facebook / Instagram) Pixel – to measure ad performance and display personalized ads.
Privacy Policy: https://www.facebook.com/privacy/policy
Ad settings: https://www.facebook.com/settings/?tab=ads

Google Ads – for remarketing and audience measurement.
Opt-out: https://adssettings.google.com

Klaviyo – we use Klaviyo Inc., 125 Summer Street, Boston MA 02110, USA, for email marketing and automation.
Data processed: email address, name, purchase history, interaction with emails and website.
Privacy Policy: https://www.klaviyo.com/legal/privacy/privacy-notice
Data transfer to the USA is based on EU Standard Contractual Clauses. You can unsubscribe from emails at any time by using the link provided in each email.

We do not use Shopify Audiences or similar tools that would share personal data with other merchants.

You can also opt out of interest-based advertising in general at:
https://optout.aboutads.info or https://www.youronlinechoices.com.

5. using personal information

We use your personal data to provide and improve our services, including:

- providing access to digital products and processing payments;

- sending order confirmations and download links;

- offering customer support;

- sending information about updates, new products or educational content (if you have subscribed to our newsletter).

Lawful basis

- Contract performance (Art. 6 (1) b) – for processing purchases and providing digital content.

- Legal obligation (Art. 6 (1) c) – for tax and accounting retention duties.

- Consent (Art. 6 (1) a) – for email marketing or analytics tracking.

- Legitimate interest (Art. 6 (1) f) – for maintaining IT security and preventing fraud.

Retention

We store personal data only for as long as necessary to fulfil contractual or legal obligations.
Billing data are retained according to statutory requirements (usually 10 years under German tax law).
Marketing-related data are deleted when you withdraw your consent or unsubscribe.

Automatic decision-making

We do not use automated decision-making or profiling that produces legal or significant effects on you. Shopify may apply limited automated checks (e.g., temporary IP blacklists) to prevent payment fraud; these do not affect your rights or access to our services.

6. no sale of personal information

We do not sell personal data to third parties within the meaning of applicable data protection laws (especially the GDPR).
Your data is only shared with service providers who are contractually bound to process it on our behalf (e.g. hosting providers, payment processors, analytics tools) and solely for the purposes described in this Privacy Policy.

Data will only be transferred to third countries (e.g. USA) if an adequate level of protection exists or EU Standard Contractual Clauses have been concluded.

We also do not engage in profiling or automated decision-making that produces legal or similar significant effects on you.

7. your rights

Under the General Data Protection Regulation (GDPR), you have the following rights regarding your personal data:

- Right of access (Art. 15 GDPR) – to request confirmation whether we process your data and to receive a copy.

- Right to rectification (Art. 16 GDPR) – to have inaccurate or incomplete data corrected.

- Right to erasure (Art. 17 GDPR) – to request deletion of your data when processing is no longer necessary or you withdraw your consent.

- Right to restriction of processing (Art. 18 GDPR) – to limit processing in certain cases.

- Right to data portability (Art. 20 GDPR) – to receive your data in a structured, commonly used, and machine-readable format.

- Right to object (Art. 21 GDPR) – to object to processing based on legitimate interests or for direct marketing purposes.

- Right to withdraw consent (Art. 7 (3) GDPR) – to withdraw your consent at any time with effect for the future.

To exercise these rights, please contact us at:
E-mail: the-fashionformula@systoms.de

You also have the right to lodge a complaint with a supervisory authority, in particular in the EU member state of your habitual residence, your workplace, or the place of the alleged infringement.
In Germany, this is typically the competent Data Protection Authority of your federal state.

For more information about data processing through Shopify, please refer to Shopify’s GDPR documentation:
https://help.shopify.com/en/manual/your-account/privacy/GDPR

8. cookies

We use cookies and similar technologies on our website to ensure basic functionality, improve performance, and, with your consent, to analyze usage and display personalized content or advertising.

Legal basis:

- Necessary cookies: Art. 6 (1) f GDPR (legitimate interest).

- Analytics and marketing cookies: Art. 6 (1) a GDPR (consent).

You can manage or withdraw your consent at any time via the cookie settings displayed when you first visit our site or accessible at the footer (“Cookie settings”).

Cookie categories:

- Technically necessary cookies – enable website operation, checkout, login and language settings.

- Analytics cookies – help us understand how visitors use our website (e.g. Google Analytics, Shopify Analytics).

- Marketing cookies – used for personalized ads and retargeting (e.g. Meta Pixel, Google Ads, Klaviyo tracking).

Retention:
Cookies are stored for different durations depending on type and purpose. Session cookies are deleted after closing your browser; persistent cookies remain stored until you delete them or revoke consent.

For details on cookies used by Shopify, see:
https://www.shopify.com/legal/cookies

9. changes

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, or legal requirements.

The latest version will always be available on this website under the “Privacy Policy” section.

If significant changes affect your rights or how we process your personal data, we will inform you in advance via email or a notice on our website.

10. complaints

If you believe that we have not handled your personal data in accordance with applicable data protection law, you can contact us at any time via the details listed under “Contact.”

You also have the right to lodge a complaint with a data protection supervisory authority, in particular in the EU member state of your habitual residence, your place of work, or the place of the alleged infringement.

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Contact

the-fashionformula@systoms.de

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