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Privacy Policy

With regard to the personal data provided by a customer/visitor to www.custom-cufflinks.co.uk (“our website”), CoinsForAnything Ltd., 120 High Road, East Finchley, N2 9ED London, England (hereinafter: “CFA”) is the responsible entity that collects and processes this data.

We describe below how we respect the privacy of all customers/visitors to this site. CFA is committed to implementing lawful data processing practices that protect your personal data. We believe that everyone benefits from a free flow of information when the relevant data is collected and used in a responsible manner.

The following statement is our privacy policy and we describe here our principles regarding the privacy of all customers/visitors to our website.

We inform you about the collection, use and processing of personal data when using our website www.custom-cufflinks.co.uk (hereinafter: “website”). Insofar as information relates exclusively to our website, we expressly draw your attention to it.

I. Type, scope and purpose of the collection, processing and use of personal data

We therefore only collect, process and use your personal data in accordance with the following data protection declaration. Personal data in this sense are all individual details about personal or factual circumstances of a specific or identifiable natural person, such as your name, your telephone number or your address.

The use of custom-cufflinks.co.uk services is on a voluntary basis. Without the provision of all these data in accordance with clauses III.1 to III.4, various services can only be used to a limited extent. For this reason, CFA grants users of these services the highest possible standard of data protection. The collection, processing, storage and use of the generated data is exclusively for the purposes stated here.

Within the scope of using the services of custom-cufflinks.co.uk, CFA processes and stores usage data that is intended to provide information about how or when users use the service. This mainly includes log data, which shows when the user has logged into the service.

We use this data to provide you with the service you have requested. For this purpose, it may be necessary to pass on your personal data to companies that we use or arrange for the provision of the service or the execution of the contract. These are, for example, service providers. They only receive the necessary data from us and are in turn obliged to protect your personal data. We need your e-mail address so that we can confirm all necessary information regarding an order and communicate with you (e.g. for sending an ordered newsletter). External service providers may also be used for services that do not directly serve the provision of services requested by users, such as the implementation of marketing measures, which may have their registered office outside the European Union. In such cases, information is passed on to these companies or individuals in order to enable them to carry out further processing. An extract of the relevant companies can be found in section V. (External service providers incl. information on cookies). The relevant service providers are carefully selected by us, linked by legally compliant contracts and regularly checked. The service providers may only use the data for the purposes specified by CFA.

We observe the principle of purpose-bound data use and collect, process and store your personal data only for the purposes you have requested. Your personal data will not be passed on to third parties without your express consent, unless this is necessary for the provision of the service or the execution of the contract. Data will also only be passed on to state institutions and authorities entitled to receive information within the scope of the statutory duty to provide information or if we are obliged to provide information by a court decision.

Insofar as we use data for a purpose that requires your consent in accordance with the statutory provisions, we will ask you for your express consent in each case. You can revoke your consent at any time and/or object to future uses of your data.

CFA does not record or collect personal data made available to us via our website in order to pass it on or sell it to third parties for marketing purposes or to use it for host mailings carried out on behalf of third parties.

CFA ensures the confidentiality and security of this information to the extent that it is used in the course of business. Access to this data is restricted and we use technical and organisational security measures to protect the data against loss, misuse and improper disclosure.

We would like to point out that data transmission on the Internet (e.g. communication by e-mail) can have security gaps. Complete protection of data against access by third parties is not possible.

II. Responsible body

The responsible party for the collection, processing and use of personal data within the meaning of the Federal Data Protection Act is:

CoinsForAnything Ltd., 120 High Road, East Finchley, N2 9ED London, England.

E-Mail: datasecurity@coinsforanything.co.uk

If you have any questions regarding the processing of your personal data, please contact our Data Protection Officer, Christian Hemmrich.

III. Notice for children and adolescents

Persons under the age of 18 may submit an enquiry, but the products cannot be effectively purchased by the person with limited legal capacity. The consent of the legal representatives is required for this.

IV. Consent

The collection, processing, use and storage of data (type, scope and purpose of the collection, processing and use of personal data) only takes place if CFA is legally entitled to do so or the user has expressly consented to this beforehand. The content of the declarations of consent, which can be revoked at any time and are logged by CFA , can be accessed by the user at www.custom-cufflinks.co.uk/privacy-policies/. The user also has the option to revoke his consent to this data protection declaration at any time. With regard to the deletion of data already generated, point XII. (Blocking and deletion) applies.

V. Data collection for informational use of our website

You can visit our website and obtain information without having to provide any personal details. However, each time you access the CFA pages, usage data is transmitted by the respective internet browser and stored in log files, the so-called server log files. No personal data, with the exception of the data transmitted by your browser or the end device you are using, is collected to enable your visit to our website. The following data is transmitted to CFA:

  • IP address
  • Date and time of the request
  • Time zone difference to Greenwich Mean Time (GMT)
  • Content of the request (specific page)
  • Access status/http status code
  • Amount of data transferred
  • Website (from which the request came)
  • Browser
  • Operating system
  • Language and version of browser software
  • Advertising Identifier (IDFA)

The IP addresses of the users are deleted or anonymised after the end of use. In the case of anonymisation, the IP addresses are changed in such a way that the individual details about personal or factual circumstances can no longer be assigned to a specific or identifiable natural person or can only be assigned to such a person with a disproportionate amount of time, cost and effort. We evaluate these log file data records in anonymised form in order to further improve our offer and make it more user-friendly, to find and correct errors more quickly and to control server capacities. For example, we can track at which times the CFA website is particularly popular and provide the corresponding data volume to guarantee you the fastest possible access.

In addition, cookies are set on your terminal device when you use our website. You can find more information about the cookies used under IX.

VI. Data processing in the context of ordering CFA products

1. Data collection and processing in the event of a CFA medal production enquiry

For the purpose of enquiring about a CFA medal order (“Enquiry”), you voluntarily provide personal information and the following data will be collected, used and processed:

  • Company
  • First and last name
  • Street
  • Postcode
  • City
  • Country
  • E-mail address
  • Telephone number
  • Individual enquiry text

Your data will be passed on to the shipping company commissioned with the delivery of the medals, insofar as this is necessary for the delivery of your postal item.

We use this data to fulfil your order in accordance with the contract or to provide you with the requested service. For this purpose, it may be necessary to pass on your personal data to companies that we use or arrange for the provision of the service or the processing of the contract. These are, for example, service providers. They only receive the necessary data from us and are in turn obliged to protect your personal data. We need your e-mail address so that we can confirm receipt of your order and communicate with you (e.g. for sending an ordered newsletter). For services that do not directly serve the provision of services requested by users, such as in the areas of hosting or the implementation of marketing measures, external service providers may be used who may have their registered office outside the European Union. In such cases, information is passed on to these companies or individuals in order to enable them to carry out further processing. An excerpt of the relevant companies can be found in section IX (External service providers including information on cookies). The relevant service providers are carefully selected by us, linked by legally compliant contracts and regularly checked. The service providers may only use the data for the purposes specified by CFA.

VII. Payment service providers

For the processing of payments in the context of the use of our products and services, CFA makes use of various payment service providers who collect, store and process the data in each case:

  • Payment with PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, 2449 Luxembourg. In order to use this service, PayPal collects, stores and processes your personal data, such as your name, address, telephone number and email address, as well as your credit card or bank account details. PayPal is solely responsible for the protection and handling of the data collected by PayPal. The PayPal terms of use and data protection principles apply, which you can access at www.paypal.com/de/cgi-bin/marketingweb .
  • Payment by credit card: When paying by credit card, the payment is processed via Stripe by the payment service provider Stripe Payments Europe Ltd, Block 4, Harcourt Centre, Harcourt Road, Dublin 2, Ireland. You can find more information about Stripe’s data protection at https://stripe.com/de/privacy#translation . For the use of this service, Stripe collects, stores and processes your personal data such as your name, address, telephone number and email address as well as your credit card or bank account details. Stripe is solely responsible for the protection and handling of the data collected by Stripe.

VIII. Use of cookies on our website

CFA uses so-called “cookies” on the website, i.e. text files that are stored on your access device. Cookies are smaller files with text information that are stored on your hard drive while you are accessing the website. Cookies are used on certain pages of our website to track your interests when using the internet. This allows us to understand what is important to you and to better tailor our content to you.

However, cookies are also used to store visitors’ preferences. This allows us to tailor the content of our website to the needs of our customers. We cannot use cookies to establish a link to customers. Cookies are not used to determine the identity of people who merely visit our website. You can deactivate the option to store these cookies at any time in the system settings of your browser and delete existing cookies. Every user can also view the offer without cookies. However, not accepting cookies may limit the functionality of the website.

Some of the cookies we use are automatically deleted from your hard drive at the end of the browser session (end of session) (session cookies). In addition, we also use cookies that remain on your hard drive for a certain period of time beyond the browser session (persistent cookies). When you visit our website again, it will then automatically recognise which country and language you selected during your last visit. These persistent cookies are stored on your hard drive and deleted by the browser after the specified time. The cookies may also be those of third-party providers (third-party cookies).

We inform you about the use of cookies when you (first) visit our website. You can prevent the use of cookies at any time with effect for the future by deleting the cookies and refusing to accept cookies in your browser settings.

IX. Social Plugins

In this context, we would like to point out that CFA is not liable for any kind of misuse of this personal information by third parties.

In the case of links to social media platforms of third parties or private individuals, which are managed on separate servers, CFA has no control over the presentation and use of the content provided there. CFA accepts no liability for the accuracy and use of content provided on these servers. The linking to a third party website does not imply any recommendation or endorsement by CFA of the relevant third party or the third party’s products and services.

CFA accepts no liability for the storage and/or use of customer data on the servers of third-party providers. We recommend that you familiarise yourself with the privacy policies of the respective third-party providers to which we link.

1. Use of Facebook plugins on our website

Plugins of the social network Facebook (Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland) are integrated on our services. You can recognise the Facebook plugins by the Facebook logo or the “Like” button (“Like”) on our site. You can find an overview of the Facebook plugins here: http://developers.facebook.com/docs/plugins/

When you visit our services and click on the Facebook plugin, a direct connection is established between your browser and the Facebook server. Facebook thereby receives the information that you have visited our site with your IP address. If you click the Facebook “Like” button while logged into your Facebook account, you can link the content of our pages on your Facebook profile. This allows Facebook to associate the visit to our services with your user account. We would like to point out that we, as the provider of the services, have no knowledge of the content of the transmitted data or its use by Facebook. If a user is not a member of Facebook, there is still the possibility that Facebook will find out and store his or her IP address.

Further information on this can be found in Facebook’s privacy policy at

http://de-de.facebook.com/policy.php

If a user is a Facebook member and does not want Facebook to collect data about him or her via this offer and link it to his or her membership data stored with Facebook, he or she must log out of Facebook before visiting the website. Further settings and objections to the use of data for advertising purposes are possible within the Facebook profile settings:

https://www.facebook.com/settings?tab=ads.

2. Use of Facebook pixel on our website

On our website, we use the “visitor action pixel” of Facebook Inc, 1601 S. California Ave, Palo Alto, CA 94304, USA (“Facebook”). With its help, we can track the actions of users after they have seen or clicked on a Facebook ad. This allows us to track the effectiveness of Facebook ads for statistical and market research purposes. The data collected in this way is anonymous to us, which means that we do not see the personal data of individual users. However, this data is stored and processed by Facebook, which we will inform you about according to our level of knowledge.

Facebook may associate this data with your Facebook account and may also use it for its own advertising purposes, in accordance with Facebook’s Data Use Policy.

https://www.facebook.com/about/privacy/ . You may allow Facebook and its partners to serve ads on and off Facebook. A cookie may also be stored on your computer for these purposes.

Please email us at datasecurity@coinsforanything.co.uk if you wish to withdraw your consent.

X. Use of tracking technologies

1. Use of Google Analytics and Google Tag Manager on our website

Our website uses Google Analytics and Google Tag Manager, web analytics services provided by Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (hereinafter: “Google”). Google Analytics and Google Tag Manager use “cookies”, which are text files placed on your computer/smartphone, to help the website analyse how users use the site. The information generated by the cookie about your use of our website is usually transmitted to a Google server in the USA and stored there. On our website, however, your IP address will be shortened beforehand by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area.

Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. On behalf of the operator of this website, Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity and providing other services relating to website activity and internet usage to the website operator. The IP address transmitted by your browser as part of Google Analytics and Google Tag Manager will not be merged with other Google data.

You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. Furthermore, you can prevent the collection of the data generated by the cookie and related to your use of our website (incl. your IP address) to Google as well as the processing of this data by Google by downloading and installing the browser plugin available under the following link:

http://tools.google.com/dlpage/gaoptout

For more information, please visit:

www.google.com/intl/de/analytics/privacyoverview.html

2. Use of Double Click by Google on our website

Our website uses DoubleClick by Google as a remarketing and bid management technology. Doubleclick by Google is a service provided by Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). Doubleclick by Google uses cookies to present you with advertisements that are relevant to you. In the process, a pseudonymous identification number (ID) is assigned to your browser in order to check which advertisements were displayed in your browser and which advertisements were called up. The cookies do not contain any personal information. The use of DoubleClick cookies only enables Google and its partner websites to serve ads based on previous visits to our website or other websites on the Internet. The information generated by the cookies is transferred by Google to a server in the USA for evaluation and stored there. A transfer of data by Google to third parties only takes place on the basis of legal regulations or within the framework of commissioned data processing. Under no circumstances will Google combine your data with other data collected by Google.

By using our website, you consent to the processing of data about you by Google and the manner in which it is processed and for the purposes set out above. You can prevent cookies from being stored by setting your browser software accordingly.

However, we would like to point out that in this case you may not be able to use all the functions of our website to their full extent. Furthermore, you can prevent the collection of the data generated by the cookies and related to your use of the websites to Google as well as the processing of this data by Google by following the link below:

 www.adssettings.google.com/anonymous under the item DoubleClick deactivation extension and install the browser plugin available.

Alternatively, you can deactivate the DoubleClick cookies on the Digital Advertising Alliance page under the following link:

www.aboutads.info/choices/

3. Use of Bing Ads on our website

On our website we use technologies from Bing Ads (bingads.microsoft.com), which are provided and operated by Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA (“Microsoft”). Microsoft sets a cookie on your terminal device if you have accessed our website via a Microsoft Bing advertisement. In this way, Microsoft Bing and we can recognise that someone has clicked on an advertisement, been redirected to our website and reached a previously determined target page (conversion page). We only learn the total number of users who clicked on a Bing ad and were then redirected to the conversion page. Microsoft collects, processes and uses information via the cookie, from which usage profiles are created using pseudonyms. These usage profiles are used to analyse visitor behaviour and are used to display advertisements. No personal information about the identity of the user is processed.

If you do not want Microsoft to use information about your behaviour as described above, you can refuse the setting of cookies required for this purpose – for example, by selecting a browser setting that generally disables the automatic setting of cookies. You can also prevent the collection of data generated by the cookie and related to your use of the website, as well as the processing of this data by Microsoft, by declaring your objection at the following link: www.choice.microsoft.com/de-DE/opt-out.

Further information on data protection and the cookies used by Microsoft and Bing Ads can be found on the Microsoft website

privacy.microsoft.com/de-de/privacystatement .

4. Use of Facebook Custom Audiences on our website

The communication tool Website Custom Audiences from Facebook is used on our website. For this purpose, so-called Facebook pixels are integrated on our websites, which mark you as a visitor to our website in anonymised form, i.e. without identifying you as a person. If you are later logged in to Facebook, a non-reversible and therefore non-personal checksum (hash value) from your usage data is transmitted to Facebook for analysis and marketing purposes. This enables Facebook to assign the visit to our pages to your user account. We can use the information obtained in this way to display Facebook Ads. For the Website Custom Audiences product, the Facebook cookie is addressed.

For more information about the purpose and scope of data collection and the further processing and use of the data by Facebook, as well as your setting options for protecting your privacy, please refer to Facebook’s privacy policy at: www.facebook.com/ads/website_custom_audiences/ and

https://www.facebook.com/privacy/explanation.

If you do not want information about your behaviour to be used by Facebook Custom Audience, you can set this under your Facebook account via this link: www.facebook.com/ads/website_custom_audiences/ einstellen.

XI. Retargeting – Use of Google Adwords (Remarketing / Conversion Tracking) on our website

CFA uses the Google Adwords service from Google. Our website uses the remarketing function of Google Adwords. This function is used to present interest-based advertisements to website visitors within the Google advertising network. The browser of the website visitor saves so-called “cookies”, text files that are stored on your end device and which make it possible to recognise the user when he or she visits websites that belong to the Google advertising network. On these pages, the user can then be presented with advertisements that relate to content that the visitor has previously accessed on websites that use Google’s remarketing function.

According to its own information, Google does not collect any personal data during this process. However, if you do not wish to use Google’s remarketing function, you can deactivate it by making the appropriate settings at:

www.google.com/settings/ads . Alternatively, you can deactivate the use of cookies for interest-based advertising via the advertising network initiative by following the instructions at:

www.networkadvertising.org/managing/opt_out.asp

Further information on Google Remarketing and Google’s privacy policy can be found at:

www.google.com/privacy/ads/ .

XII. E-mail newsletter

With our e-mail newsletter we inform you about our offers. If you would like to receive the e-mail newsletter, we require an e-mail address from you. We will only send you our newsletter if you expressly agree to this when you open a customer account. In doing so, we will check whether you are the owner of the e-mail address provided or whether the owner of the e-mail address agrees to receive the e-mail newsletter.

By subscribing to our newsletter, you agree to receive it and to the procedures described. We send newsletters and e-mails with promotional information (hereinafter “newsletters”) only with the consent of the recipients or a legal permission.

Furthermore, our newsletters contain information about interesting medal projects of the past, new products and manufacturing techniques as well as about CFA itself. This includes references to blog articles, publications, trade fair appearances, events, our services or online appearances.

Double opt-in and logging

Registration for our newsletter takes place in a so-called double opt-in process. This means that after registration you will receive an e-mail asking you to confirm your registration. This confirmation is necessary so that no one can register with other email addresses.

The registrations for the newsletter are logged in order to be able to prove the registration process in accordance with the legal requirements. This includes the storage of the registration and confirmation time, as well as the IP address. Changes to your data stored with CleverReach are also logged.

Use of the “CleverReach” dispatch service provider

The newsletter is sent using “CleverReach”, a newsletter dispatch platform of the German provider CleverReach GmbH & Co. KG, Mühlenstr. 43, 26180 Rastede, Germany.

The email addresses of our newsletter recipients, as well as their other data described in this notice, are stored on Cleverreach’s servers. CleverReach uses this information to send and evaluate the newsletter on our behalf. Furthermore, CleverReach may, according to its own information, use this data to optimise or improve its own services, e.g. for the technical optimisation of the dispatch and presentation of the newsletters or for economic purposes in order to determine from which countries the recipients come. However, CleverReach does not use the data of our newsletter recipients to write to them itself or to pass it on to third parties.

We trust in the reliability and IT and data security of CleverReach. All CleverReach data centres have undergone independent certifications and audits. They have received DIN ISO/IEC 27001 certification and have been confirmed as a Level 1 service provider for the credit card industry’s data security standard (DSS/PCI). In addition, they undergo annual SOC 1 audits and have been successfully confirmed at the Moderate level for US government systems and at DIACAP Level 2 for DoD systems. CleverReach uses a TUV-approved Information Security Management System, which ensures excellent data security and impeccable data protection compliance.

CleverReach’s privacy policy can be found at:

https://www.cleverreach.com/de/datensicherheit

Registration data

To register for the newsletter, it is sufficient to enter your e-mail address. Optionally, we ask you to enter your first and last name. This information is only used to personalise the newsletter.

Statistical collection and analyses

The newsletters contain a so-called “web beacon”, i.e. a pixel-sized file that is retrieved from the CleverReach server when the newsletter is opened. Within the scope of this retrieval, technical information, such as information on the browser and your system, as well as your IP address and the time of the retrieval are initially collected. This information is used for the technical improvement of the services based on the technical data or the target groups and their reading behaviour based on their retrieval locations (which can be determined with the help of the IP address) or the access times.

Statistical surveys also include determining whether newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to the individual newsletter recipients. However, it is neither our intention nor that of CleverReach to observe individual users. The analyses serve us much more to recognise the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.

Online access and data management

There are cases where we direct newsletter recipients to CleverReach’s websites, e.g. our newsletters contain a link with which newsletter recipients can call up the newsletters online (e.g. in the event of display problems in the email programme). Furthermore, newsletter recipients can subsequently correct their data, such as the e-mail address. Likewise, CleverReach’s privacy policy can only be accessed on their site.

In this context, we would like to point out that cookies are used on CleverReach’s websites and that personal data is thus processed by CleverReach, its partners and service providers used (e.g. Google Analytics). We have no influence on this data collection. For further information, please refer to the CleverReach privacy policy. We would also like to draw your attention to the possibility of objecting to the collection of data for advertising purposes on the websites www.aboutads.info/choices/ and www.youronlinechoices.com/ (for the European region).

Cancellation/revocation

You can cancel the receipt of our newsletter at any time, i.e. revoke your consent. At the same time, your consent to the sending of the newsletter via CleverReach and the statistical analyses will expire. Unfortunately, it is not possible to separately cancel the sending of the newsletter via CleverReach or the statistical analysis.

You will find a link to cancel the newsletter at the end of each newsletter.

In accordance with the requirements of the Basic Data Protection Regulation (DSGVO) applicable from 25 May 2018, we inform you that consent to the sending of e-mail addresses is given on the basis of Art. 6 Para. 1 lit. a, 7 DSGVO as well as § 7 Para. 2 No. 3, or Para. 3 UWG. The use of the dispatch service provider CleverReach, the performance of statistical surveys and analyses as well as the logging of the registration process are based on our legitimate interests pursuant to Art. 6 para. 1 lit. f DSGVO. We are interested in the use of a user-friendly and secure newsletter system that serves our business interests and meets the expectations of users.

XIII. Transfer of Personal Data Abroad

If CFA transfers personal data to countries outside the scope of Directive 95/46/EC of the European Parliament and of the Council of 24 October 1995 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, CFA shall ensure that the recipient of the data guarantees an adequate level of data protection. When transferring data to the USA, CFA will oblige the recipient to observe and comply with the Privacy Shield principles (i.e. to recognise minimum standards in the handling of personal data). In addition, to ensure an adequate level of protection for the recipient of the data, we use the European Union’s model contracts for the transfer of data to other EU countries, as amended from time to time.

XIV Information, correction, deletion and revocation

You have the right at any time to free information about your stored personal data, its origin and recipient and the purpose of the data processing. In addition, you have the right to correction, blocking or deletion of your personal data in the legally regulated cases of § 35 BDSG. CFA points out that in order to authenticate a person, appropriate documents can be requested before providing information, as personal data may not be released to unauthorised persons.

If you have given your consent to the use of data, you can revoke this consent at any time with effect for the future. The revocation of consent may mean that our services are no longer available to you without restriction or that the user relationship is terminated. Please note that certain data collection and storage may also be based on a legal basis, irrespective of the existence of consent. In this case, we will discontinue any further processing and use of your personal data and delete or block it, unless we are obliged by law to continue processing, in particular to continue storing it.

Please direct all information requests, information questions or objections to data processing by E-Mail datasecurity@coinsforanything.co.uk or in writing to the address given in the imprint.

XV. Changes to this policy

CFA may amend this privacy statement as necessary. If changes are made to the statement, it may take up to 30 business days for new privacy practices to be implemented. Please visit this page periodically to identify any changes.

21.05.2018