1. Owner and Data Controller
2. Types of Data collected, and its use
a) When visiting the website
When you visit the Ralunar website, the browser you are using on your device automatically sends information to the server for our website. This information is temporarily stored in a log file. The following information is automatically collected and subsequently automatically deleted after a period of 20 weeks:
We process the aforementioned data for the following purposes:
We never use collected data to reference you as a person. In the event of an attack on our network infrastructure however, your IP address will be identified in order to assert or defend against legal claims.
We process data in accordance with our legitimate interests in line with Article 6 para. 1 sentence 1 item f of the General Data Protection Regulation (GDPR). Our legitimate interests proceed from the data collection purposes specified above.
b) Registering as a user on our platform
Buyers, sellers and partners can create a user account on our platform. The mandatory data required to set up a user account must be entered under i), ii) and iii). This data is processed
The data specified under points i), ii) and iii) are processed upon your placement of an inquiry for the purposes outlined above and are required for use of the platform in accordance with Article 6 para. 1 sentence 1 item b of the GDPR, and thus required for fulfilment of the contract and of pre-contractual actions.
You may have the option of providing voluntary information/data depending on the type of user account. We process voluntarily provided information/data in accordance with our legitimate interests in line with Article 6 para. 1 sentence 1 item f GDPR. This information/data is used to facilitate contact with you and ensure rapid clarification of any questions.
After deletion of your user account your data are automatically deleted to prevent further use unless, in accordance with Article 6 para. 1 sentence 1 item c GDPR, it must be stored for a longer period of time pursuant to retention and documentation requirements under tax or commercial code (HGB, StGB, AO), or if you have consented to storage for a longer period of time in line with Article 6 para. 1 sentence 1 item a GDPR.
i) User accounts
The following mandatory data must be entered to register as a user (buyer) and set up a user account:
These constitute the login data for your user account.
You can also provide this voluntary user data:
To place sale offers as a seller you must first have a user account.
The store information and data must be entered to register as a partner during the signup process.
c) Automated customer profile creation
We create a customer profile for your user account in order for you to use our platform as a registered user/merchant. We categorize your customer profile and supplement it with additional data so that you only receive information likely to be of interest to you. To do so we utilize this data:
We process the aforementioned data for the following purposes:
We process data in accordance with our legitimate interests in line with Article 6 para. 1 sentence 1 item f GDPR. Data processing for the aforementioned purposes is a recognized legitimate interest in accordance with the GDPR.
You may file objection to the creation of a user profile and/or the evaluation and personalization of our services or advertising at any time by clicking on this link, in which case processing will be stopped and your user profile will be immediately deleted unless you have consented to longer data retention per Article 6 para. 1 sentence 1 item a GDPR.
You may alternatively file objection at any time via e-mail to firstname.lastname@example.org.
d) Using Checkout service
To pursue and conclude sales contracts with sellers and partners via our Checkout service you must first have a user account (see item 2.b)i) ). The following data must also be provided, without exception:
We process the aforementioned data for the following purposes:
When you place a purchase inquiry with a seller or conclude a purchase agreement with that seller, we transfer your personal data to the seller for the purposes outlined above.
Your data as specified above is processed upon your placement of an inquiry for the purposes outlined above and is required for use of the platform in accordance with Article 6 para. 1 sentence 1 item b of the GDPR, and thus required for fulfilment of the contract and of pre-contractual actions.
e) Registering for our newsletter
We use your e-mail address to send you our personalized regular newsletter if you have expressly consented thereto in accordance with Article 6 para. 1 sentence 1 item a GDPR. To receive the newsletter it suffices to provide your e-mail address.
To receive more personalized newsletter content you can create a customer profile about you based on your collected personal data. This data relates to personal preferences such as product affinities observed on the basis of orders, interests, purchase decisions, preferred shopping time, etc. and is automatically processed and analyzed so that relevant offers are predicted for you. Profiling may also be performed without consent on the basis of Article 6 para. 1 item f GDPR given a legitimate interest).
We may also use your e-mail address without your express consent to send you information about similar products of our company if you are an existing customer and have not objected to the use of your e-mail address. Processing for purposes of marketing to existing customers is done on the basis of our legitimate interests in accordance with Article 6 para. 1 sentence 1 item f GDPR. Processing of your e-mail address for the purpose of direct marketing is a statutorily recognized interest under the GDPR.
In either case you can unsubscribe at any time, such as via link at the end of each newsletter. Alternatively, you can unsubscribe at any time by e-mail to email@example.com.
f) Using our contact form
You can use a form provided on the website to contact us with questions or contact a seller or partner. If you wish ask your question to a merchant or private seller, we forward your contact inquiry to them. For the use of the contact form, the following data is required, without exception:
We process the aforementioned data for the following purposes:
Additionally, you can voluntarily provide your name and telephone number to enable quicker contact.
When you use our contact form, we may scan and analyze your message. This is done for fraud prevention purposes and to generally improve communication and customer service.
Data is processed upon placement of your inquiry, and such processing is required for the above purposes to fulfil the contract and pre-contractual actions in accordance with Article 6 para. 1 p. 1 item b GDPR. Data from contact inquiries is also processed on the basis of our legitimate interests per Article 6 para. 1 sentence 1 item f GDPR. These interests proceed from the aforementioned purposes.
Personal data we collect when you use the contact form is automatically deleted upon completion of your inquiry.
3. Disclosure of data
We only disclose your personal data to third parties if:
4. Visibility of your data to third parties
a) As user and seller
Personal data stored in connection with your user account (myaccount, see items 2.b) i) and ii) ) cannot be viewed by third parties unless you have published offers on the platform. When you publish an offer on the platform as a private seller, registered and unregistered users will only be able to see your provider data on the platform if have expressly consented to their publishing in accordance with Article 6 para. 1 sentence 1 item a GDPR.
b) As seller
If you are registered as a seller and publish offers on the platform, registered and unregistered users can view your provider data on the platform (as per item 2.b) iii)). You can restrict the visibility of your data during registration so that your address is not displayed, and thereafter in your profile settings.
The publication of the seller data is required to fulfil and execute the contract between Ralunar and the merchant as part of use of the platform in accordance with Article 6 para. 1 sentence 1 item b GDPR.
5. Cookies and pixels
We utilize ‘cookies’ and ‘pixels’ or ‘tracking pixels’ on our website to record statistics on website usage and evaluate these for the purpose of optimizing our offering (see item b).). These enable us to automatically recognize you have previously visited our website when you revisit it.
Your data are processed using cookies and pixels for the purposes specified above on the basis of our legitimate interests and those of third parties, in line with Article 6 para. 1 sentence 1 item f GDPR, according to which these interests qualify as legitimate.
Cookies are small files automatically created by your browser which are stored on your device (laptop, tablet, smartphone, etc.) when you visit our website. Cookies do not harm your device and do not contain viruses, Trojans or other malicious software.
Cookies store data about the specific device used for the respective website visit. This does not mean that we are able to directly discern your identity.
Cookies are in part utilized to enable us to enhance our offer for you. For example, we utilize what are known as ‘session cookies’ to recognize that you have already visited individual pages of our website, or have already logged in to your user account. These cookies are automatically deleted when you leave our website.
We also use temporary cookies which are stored on your device for a specific period of time in order to improve the user experience. When you revisit our site to utilize our services, these automatically register that you have visited before and the entries and settings you have made so that you do not have to re-configure these.
Most browsers are configured by default to accept cookies. You can configure your browser so that cookies are not stored on your computer, or so you receive notification before each new cookie is created. Disabling cookies can however mean that you are unable to utilize some features of our website.
Tracking pixels or just ‘pixels’ are small 1x1-pixel GIF files that can be hidden in graphics, e-mails, etc. when visiting a website. Pixels do not harm your device and do not contain viruses, Trojans or other malware.
Pixels send your IP address, the referrer URL of the website visited, the time the pixel was viewed, the browser used, and previously set cookie information to a web server. This enables us measure reach and conduct other statistical analyses for the purpose of optimizing our platform and offerings.
Most browsers automatically accept pixels. You can use certain tools and browser add-ons to block the use of pixels on our webpages (like the AdBlock add-on for the Firefox browser).
6. Analysis tools
a) Tracking tools
We utilize the tracking tools outlined below on the basis of Article 6 para. 1 sentence 1 item f GDPR. We deploy these tracking tools to optimize our website design on an ongoing basis to better meet user needs. In addition we use tracking tools to record website usage statistics which we analyze in order to optimize our offering for you. These interests qualify as legitimate under the provision cited above.
The data processing purposes and data types are as per the respective tracking tools.
i) Google Analytics
are transmitted to a Google server in the US and stored there. Google is subject to the EU-US Privacy Shield, which guarantees an appropriate level of privacy.
This information is used to analyze use of the website, compile reports on website activity and provide additional services related to website activity and internet usage for the purposes of market research and website design in accordance with user needs. This information may be forwarded to third parties as required by law, and to third parties functioning as data processors. Your IP address will never be compiled with any other data held by Google. IP addresses are anonymized to render cross-referencing impossible (IP masking).
You may refuse to accept cookies by changing the settings on your browser accordingly; in such case however you may not be able to fully utilize the entire range of the features of this website.
You can also block the recording of data generated by the cookie concerning your use of the website (including your IP address) and prevent processing by Google by downloading and installing a browser add-on.
As an alternative to the browser add-on, particularly for browsers on mobile devices, you can opt out of data collection by Google Analytics by clicking on this link. An opt-out cookie is set which blocks future collection of your data when visiting this website. The opt-out cookie is stored on your device and is only valid in that browser and for our website. If you delete the cookies for that browser, the opt-out cookie has to be reset.
For more information about privacy related to Google Analytics, see the Google Analytics Help Centre.
ii) Google Adwords Conversion Tracking
We utilize Google conversion tracking to record website usage statistics and analyze these for the purpose of optimizingw our offerings. Google Adwords places a cookie on your computer (see item 5) when you navigate to our website via a Google ad. Google is subject to the EU-US Privacy Shield, which guarantees an appropriate level of data privacy.
These cookies expire after 30 days and are not used for personal identification. If a user visits certain pages of the website of the Adwords customer and the cookie has not yet expired, Google and the customer can observe that the user clicked on the ad and was redirected to this page.
Every Adwords customer receives a different cookie. Cookies thus cannot be tracked via the websites of Adwords customers. Information obtained via conversion cookie is used to prepare conversion statistics for Adwords customers who have opted for conversion tracking. Adwords customers receive information on the total number of users who have clicked on their ad and were redirected to a page bearing a conversion tracking tag. They do not however receive any information with which the user can be personally identified.
iii) VWO (Visual Web Optimizer)
You can disable collection and processing of your website usage data by VWO at any time with non-retrospective effect. An opt-out cookie is utilized for this which contains the data you do not want VWO to collect. The data is not disclosed to third parties unless there is a legal obligation to do so or the third parties have been commissioned as data processor (such as a data center).
b) Targeting tools
We utilize the targeting tools outlined below on the basis of Article 6 para. 1 sentence 1 item f GDPR. Targeting tools are used to ensure that all advertising displayed on your devices is based on your actual or predicted interests. These interests qualify as legitimate under the provision cited above.
See the sections on the respective tracking tools regarding their data processing purposes and data types.
i) Google Adwords remarketing
We utilize Google Remarketing Tags, which are a service of Google Inc. (1600 Amphitheater Parkway, Mountain View, CA 94043, USA, hereinafter "Google"). Google utilizes ‘cookies’ (see item 5), which are text files stored on your computer allowing analysis of your website usage. The information generated by the cookie about your use of this website (including your IP address) is sent to a Google server in the US and stored there. Google is subject to the EU-US Privacy Shield, which guarantees an appropriate level of data privacy.
Google then removes the last three digits of the IP address, rendering definite cross-referencing of the IP address impossible. Google will use this information to evaluate your use of the website, compile reports on website activity for website operators and provide other website and internet usage-related services.
Please be advised however that you may not be able to utilize all functionalities of this website in such case. By using this site, you consent to Google processing data gathered about you in the manner and for the purpose outlined above. Further information about Google policies can be found here.
ii) Google Double Click
Cookies are used on our website to collect and evaluate data for the purpose of optimizing advertising (see item 5). For this we use targeting technologies of Google Inc. (Double Click, Double Click Exchange Buyer, Double Click Bid Manager). These technologies enable us to serve advertising to you in targeted fashion based around your interests. The cookies are used, for example, to record information about which of our products you are interested in. Using this information we can market offers to you on our website or third-party websites which are oriented around your specific interests as predicted based on your historical user behavior. Data collected and evaluated pertaining to your user behavior exclusively on a pseudonymous basis so that it is not possible for us to identify you. In particular, this data is not merged with personal data about you.
Google is subject to the EU-US Privacy Shield, which guarantees an appropriate level of data privacy.
The cookie is automatically deleted after 30 days.
You can also configure setting for the display of interest-based advertising via the Google Ads Settings Manager.
iii) Facebook Custom Audiences
We utilize Facebook Website Custom Audiences, a service of Facebook Ireland Limited (4 Grand Canal Square, Dublin 2, Ireland). This Facebook marketing service allows us to display personalized and interest-based advertising on Facebook for particular groups of pseudonymized visitors to our website who use Facebook.
A Facebook custom audience pixel is integrated on our website. This is a Java Script code which stores non-personal data about your usage the website. This data includes your IP address, the browser you are using, and the referring and destination pages. This data is transmitted to Facebook servers in the United States. Facebook is subject to the EU-US Privacy Shield, which guarantees an appropriate level of data privacy.
In an automated process there it is checked whether you have a Facebook cookie stored. The Facebook cookie automatically determines whether you belong to the target group relevant for us. If you belong to the target group, we then show you relevant ads of ours on Facebook. In this process, you are not personally identified, either by us or by Facebook.
You can opt out of use of the Custom Audiences service on the Facebook website. After logging in to your Facebook account, go to the Facebook ads settings.
This website utilizes technologies of Criteo SA (32 Rue Blanche, 75009 Paris, France) to collect and store data for marketing and optimization purposes. We determine the purposes and means of processing jointly with Criteo, and thus are jointly responsible for processing as controller.
When Criteo is used, additional pixels of partners of Criteo are loaded as well. An overview of all publishers and networks that load pixels is provided here.
You can opt out of pseudonymous analysis of your browsing behavior at any time via us. See the Criteo link below for instructions on disabling the Criteo service.
Please be advised that if you opt out of displaying personalized ads from Criteo and other advertising affiliates, you will still receive advertisements but these will be less tailored to your interests and browsing behavior.
7. Social Media Plug-ins
We utilize social plug-ins of the social media networks Facebook, Twitter, Google+ and Instagram to promote our company on our website on the basis of Article 6 para. 1 sentence 1 item f GDPR. This promotional purpose is a legitimate interest within the meaning of the GDPR. The respective providers are responsible for ensuring operation in conformance with data protection laws.
The social media buttons are integrated with a self-developed solution. This solution prevents you from connecting to a social media network just by opening a web page with a social media button on it without pressing the button, i.e. data are not sent to the social media network unless you hit the button.
Our platform uses social media plug-ins of Facebook Ireland Limited (4 Grand Canal Square, Dublin 2, Ireland) to personalize the experience through usage of "LIKE" and "SHARE" buttons. These are a Facebook offering.
When you visit a page of our website featuring such a plug-in and you activate that plug-in yourself, your browser establishes a direct connection to Facebook servers. The plug-in content is sent by Facebook directly to your browser and integrated into the page.
When a plug-in is integrated, Facebook receives the data the browser you used to access the page of our website in question even if you do not have a Facebook account or are currently not logged in to Facebook. This data (including your IP address) is transmitted by your browser directly to a Facebook server in the US and stored there.
If you are logged into Facebook, Facebook can directly reference your visit to our website your Facebook account. If you interact with a plug-in such as by pressing a "LIKE" or "SHARE" button, the corresponding information data is also transmitted directly to a Facebook server and stored. This data is posted on Facebook and displayed to your Facebook friends.
Facebook can use this data for the purposes of advertising, market research and structuring Facebook pages in line with user needs. This involves Facebook creating user, interest and relationship profiles, for example to evaluate your use of our website in relation to advertisements displayed on Facebook, to inform other Facebook users of your activities on our website and to provide other services related to use of Facebook.
If you do not want Facebook to reference information about you from our website to your Facebook account, you must log out of Facebook before visiting our website.
Please see the Facebook data privacy notices for information regarding the purpose and scope of data collection, further processing and use of data by Facebook, your data privacy rights and data privacy configuration settings.
Plug-ins of the news and social networking firm Twitter International Company (One Cumberland Place, Fenian Street, Dublin 2, D02 AX07 Ireland, hereinafter "Twitter") are integrated into our web pages. Twitter plug-ins (Tweet button) bear the Twitter logo, making them identifiable on our website. An overview of Tweet buttons can be found here.
When you visit a page of our website featuring such a plug-in and you activate that plug-in yourself, a direct connection is established between your browser and a Twitter server. Twitter then receives the information that you have visited our page, and your IP address. You can link content from our webpages with your Twitter account by clicking on the Twitter "Tweet" button while logged into your Twitter account. This enables Twitter to cross-reference your visit to our webpages to your user account. Please note that as website provider we have no knowledge of the content of the data transmitted or regarding its use by Twitter.
You should log out of your Twitter account first if you do not want Twitter to be able to cross-reference your visit to our webpages to your Twitter user account.
Our website uses plug-ins of Google Plus, social media network operated by Google Inc. (1600 Amphitheater Parkway, Mountain View, CA 94043, USA). The plug-ins are recognizable on buttons, for example, by the characters "+1" appearing on a white or colored background. An overview of Google plug-ins and their appearance can be found here.
When you visit a page of our website featuring such a plug-in and you activate that plug-in yourself, your browser establishes a direct connection to Google servers. The plug-in content is sent by Google directly to your browser and integrated into the page. When a plug-in is integrated, Google receives the data the browser you used to access the page of our website in question even if you do not have a Google Plus profile or are currently not logged in to Google Plus. This data (including your IP address) is transmitted by your browser directly to a Google server in the US and stored there. If you are logged in to Google Plus, Google can directly reference your visit to our website to your Google Plus profile.
If you interact with a plug-in such as by pressing a "+1" button, the corresponding information data is also transmitted directly to a Google server and stored. This data is also published on Google Plus and displayed to your contacts there.
Please see the Google data privacy notices for information regarding the purpose and scope of data collection, further processing and use of data by Google, your data privacy rights and data privacy configuration settings.
If you do not want Google to be able to directly reference data collected about your visit to our website to Google Plus, you must log out of Google Plus before visiting our website. You can use browser add-ons such as NoScript (http://noscript.net/) to completely block the loading of Google plug-ins.
Our website utilizes Instagram social plug-ins ("plug-ins") operated by Instagram LLC., 1601 Willow Road, Menlo Park, CA 94025, USA ("Instagram").
The plug-ins bear an Instagram logo, such as the “Instagram camera".
When you visit a page of our website featuring such a plug-in and you activate that plug-in yourself, your browser establishes a direct connection to Instagram servers. The plug-in content is sent by Instagram directly to your browser and integrated into the page. When a plug-in is integrated, Instagram receives the data the browser you used to access the page of our website in question even if you do not have an Instagram profile or are currently not logged in to Instagram.
This data (including your IP address) is transmitted by your browser directly to an Instagram server in the US and stored there. If you are logged into Instagram, Instagram can directly reference your visit to our website your Instagram account. If you interact with a plug-in such as by pressing an Instagram button, the corresponding information data is also transmitted directly to an Instagram server and stored.
This data is also published on your Instagram account and displayed to your contacts there.
If you do not want Instagram to directly reference information about you from our website to your Instagram account, you must log out of Instagram before visiting our website.
8. Rights as data subject:
You have the right:
9. Right to file objection
If your personal data are processed on the basis of on legitimate interests in accordance with Article 6 para. 1 sentence 1 item f GDPR, you have the right to file an objection against the processing of your personal data pursuant to Article 21 GDPR given reasons for doing so which pertain to your special circumstances or the objection pertains to direct advertising. In the latter case you enjoy a general right to file objection which we will act upon without your having to outline any special circumstances.
To exercise your right to file objection it suffices to send a corresponding e-mail to firstname.lastname@example.org.
10. Data security
We utilize the widely used TLS (Transport Layer Security) method for our website in combination with the highest level of encryption supported by your browser. TLS is a secure and proven standard utilized in online banking, for example. A secure TLS connection is indicated among other things by the letter ‘s’ appended on the ‘http’ (i.e. https://..) in the address bar of your browser, and by a lock icon appearing at the bottom of your browser.
We furthermore implement appropriate technical and organizational security measures to protect your data against accidental or intentional manipulation, partial or total loss, destruction and unauthorized access by third parties. The security measures we implement are continuously upgraded to remain in line with technological progress.
If you register with us as a user, you can only access your user account after entering your personal password. You should always keep your access data confidential and close the browser window when you have finished communicating with us, especially if you share your computer with others.
We take company-internal data protection very seriously as well. We bind our staff and commissioned service provider firms to uphold confidentiality and comply with data protection regulations.
11. Version of and changes to this Data Protection Policy
This Data Protection Policy is the latest, valid version, last updated in March 2020.
Changes to our website and offers marketed via the website and changes in legal or regulatory requirements may necessitate updating of this Data Protection Policy. You can view and print out the latest updated version of this Data Protection Policy at any time on the website