PRIVACY POLICY
 
TLC Trading GmbH, Grindelstrasse 12, CH-8303 Bassersdorf is the operator of the websites Outletonline.ch, Slimshop.ch Genialo.ch and the services offered on them and is 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 issue of data protection seriously and ensure appropriate security. Of course, we observe the legal provisions of the Federal Data Protection Act (DSG), the Ordinance on the Federal Data Protection Act (VDSG), the Telecommunications Act (TCA) and other applicable data protection provisions of Swiss or EU law, in particular the General Data Protection Regulation (GDPR).
So that you know what personal data we collect from you and for what purposes we use it, please note the information below.
 
1. Calling up our website
When you visit our website, our servers temporarily store each access in a log file. As with every connection to a web server, the following technical data is recorded without your intervention and stored by us until it is deleted after 2 months at the latest:
- 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 access was made (referrer URL), possibly 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 applicable, your username from a registration/authentication
This data is collected and processed for the purpose of enabling the use of our website (establishing a connection), ensuring system security and stability over the long term and enabling the optimization of our website, as well as for internal statistical purposes. This is our legitimate interest in data processing within the meaning of Article 6 (1) (f) GDPR.
 
2. Opening 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 password-protected direct access to the 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 processing the data for this purpose lies in the consent you have given in accordance with Article 6 (1) (a) of the EU GDPR.
 
3. Purchase in the online shop
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)
- Information in the context of the payment (depending on the selected payment method)
- Login data, i.e. e-mail address and password (for registered customers)
Unless otherwise stated in this data protection declaration or if you have not given your separate consent, we will only use the aforementioned data to process the contract, namely to process your orders, deliver the ordered products and ensure correct payment. The legal basis for data processing for this purpose lies in the fulfillment of a contract in accordance with Article 6 (1) (b) EU GDPR.
 
4. Disclosure of data to third parties
We only pass on your personal data if you have given your express consent, if there is a legal obligation to do so or if this is necessary to enforce our rights, in particular to enforce claims arising from the contractual relationship. In addition, we pass on your data to third parties insofar as this is necessary in the context of using the website and 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 who has or can have access to it is our web host Shopify (Outletonline.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 functionality of our website. This is our legitimate interest within the meaning of Art. 6 Para. 1 lit. f EU-DSGVO. If we make an advance payment, 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 processes in order to protect our legitimate interests. For this purpose, we transmit the personal data required for a credit check to the credit agency Intrum AG Eschenstrasse 12, CH-8603 Schwerzenbach and use the information received about the statistical probability of a payment default for a balanced decision on the establishment, implementation or termination of the contractual relationship. The credit report can contain probability values ​​(score values), which were calculated on the basis of scientifically recognized mathematical-statistical methods and which, among other things, include address data. Your legitimate interests will be taken into account in accordance with the statutory provisions. In the purposes described above, there is our legitimate interest in data processing within the meaning of Article 6 (1) (f) EU GDPR. Finally, when paying by credit card on the website, we forward your credit card information to your credit card issuer and to 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 mandatory information. The legal basis for passing on the data lies in the fulfillment of a contract in accordance with Article 6 (1) (b) EU GDPR. With regard to the processing of your credit card information by these third parties, we ask that you also read the general terms and conditions and the data protection declaration of your credit card issuer.
 
5. Transfer of data abroad
We are entitled to transfer your personal data to third-party companies (contracted service providers) abroad for the purpose of the data processing described in this data protection declaration. They are obliged to data protection to the same extent as we are. 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 to that in Switzerland or the EU at all times.
 
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 saves on your computer's hard drive when you visit our website. For example, we use cookies to offer you the shopping cart function across 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 you call 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 you call up another subpage. Most Internet browsers automatically accept cookies. However, you can configure your browser in such a way that no cookies are stored on your computer or that a message always appears when you receive a new cookie. On the following pages you will find explanations on how to configure the processing of cookies in 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=de
- Google Chrome for Mobile
https://support.google.com/chrome/answer/2392709?hl=de&co=GENIE.Platform%3DAndroid&oco=1
- Apple Safari for desktop
https://support.apple.com/kb/PH17191?locale=en_US&viewlocale=de_DE
- Apple Safari for Mobile
https://support.apple.com/de-de/HT201265
Deactivating cookies may mean that you cannot use all the functions of our website.
 
7. Tracking Tools
a. General
For the purpose of the needs-based design and continuous optimization of our website, we use the web analysis service from Google Analytics. In this context, pseudonymised 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 that a visitor follows on 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 access is made,
- Device (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 website activity and to provide other services related to website and internet use for the purposes of market research and needs-based 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 our behalf.
 
b. Google Analytics
The provider of Google Analytics is Google Inc., a company of the holding company Alphabet Inc, based in the USA. Before the data is transmitted to the provider, the IP address is shortened by activating IP anonymization ("anonymizeIP") on this website within the member states of the European Union or in other contracting states of the Agreement on the European Economic Area. The anonymized 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 sent to a Google server in the USA and shortened there. In these cases, we ensure through contractual guarantees that Google Inc. maintains an adequate level of data protection. According to Google Inc., under no circumstances will the IP address be associated with other data relating to the user. You can find more information about the web analysis service used on the Google Analytics website. Instructions on how to prevent the processing of your data by the web analysis service can be found at http://tools.google.com/dlpage/gaoptout?hl=de.

c. Econda Analytics
For the needs-based design and optimization of this website, solutions and technologies from econda GmbH Zimmerstr. 6 DE-76137 Karlsruhe collects and stores anonymized data and creates user profiles from this data using pseudonyms. Cookies can be used for this purpose, which enable the recognition of an Internet browser. However, usage 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 upon receipt, which means that usage profiles cannot be assigned to IP addresses. Visitors to this website can object to this data collection and storage at any time for the future. The objection only applies to the device and the web browser on which it was set, please repeat the process on all devices if necessary. If you delete the opt-out cookie, requests will be sent to conda again.
 
8. Retargeting
For the use of retargeting and banner advertising, we use third-party services that set cookies on our site. The providers are:
- 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 Amphitheater Parkway, Mountain View, CA 94043, USA; https://www.google.de/intl/de/policies/technologies/ads/ 

9. Conversion measurement with the visitor action pixel from Facebook
With your consent, we use the "visitor action pixel" of Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA ("Facebook") on our website. With its help, we can track the actions of users after they have seen or clicked on a Facebook ad. This enables us to record 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 will inform you according to our level of knowledge. Facebook can connect this data to your Facebook account and also use it for its own advertising purposes, in accordance with Facebook's data usage guidelines https://www.facebook.com/about/privacy/. You can enable Facebook and its partners to place advertisements on and outside of Facebook. A cookie can also be stored on your computer for these purposes.

10. Newsletter Marketing
Customers have the option of subscribing to our electronic newsletter. If you do not wish to receive any further newsletters, you can simply unsubscribe from the mailing list by clicking the "Unsubscribe" button. We use the third-party provider CleverReach GmbH & Co. KG Mühlenstr. to send and create the newsletter. 43 DE-26180 Rastede. The company provides us with evaluation tools with which we can measure the success of the newsletters sent.
The information generated by the cookie is transmitted to the server of the provider of these services, stored there and processed for us. Among other things, the following information is recorded: Opening and clicking behavior.

11. Notice Regarding Data Transfers to the United States
For the sake of completeness, we would like to point out to users who are resident or have their registered office in Switzerland that there are surveillance measures by US authorities in the USA that generally require the storage of all personal data of all persons whose data was transmitted from Switzerland to the USA. allows. This is done without differentiation, limitation or exception based on the objective pursued and without an objective criterion that makes it possible to limit the US authorities' access to the data and their subsequent use to very specific, strictly limited purposes that - be able to justify the interference associated with access to and use of this data. In addition, we would like to point out that there are no legal remedies in the USA for data subjects from Switzerland that would allow them to gain access to the data concerning them and to obtain their correction or deletion, or no effective judicial legal protection against general access rights of US authorities. We explicitly draw the data subject's attention to this legal and factual situation in order to make an appropriately informed decision to consent to the use of his data. We would like to point out to users residing in an EU member state that the USA does not have an adequate level of data protection from the point of view of the European Union - partly due to the issues mentioned in this section. Insofar as we have explained in this data protection declaration that recipients of data (such as Google) are based in the USA, we are either contractually affiliated with these companies or by ensuring that these companies are certified under the EU or Swiss-US -Privacy shield ensure that your data is protected with an appropriate level with our partners.
 
12. Right to information, correction, deletion and restriction of processing; Right to data portability
You have the right to request information about the personal data that we have stored about you. In addition, you have the right to correct incorrect data and the right to delete your personal data, provided that there is no legal obligation to retain or a legal basis that allows us to process the data. You also have the right to request that we return the data you have given us (right to data portability). Upon request, we will also pass on the data 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 aforementioned purposes via the e-mail address info@tlc-trading.ch. We may, at our discretion, request proof of identity in order to process your requests.
 
13. Data Security
We use appropriate technical and organizational security measures to protect your personal data stored by 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 if you share the computer with others. We also take internal data protection very seriously. Our employees and the service companies commissioned by us have been sworn to secrecy and to compliance with data protection regulations.
 
14. Retention of Data
We only store personal data for as long as is necessary to use the tracking and analysis services mentioned above and further processing within the scope of our legitimate interest. We keep contract data longer because this is required by statutory retention requirements. Storage obligations, which oblige us to store data, result from accounting and tax regulations. According to these regulations, business communication, concluded contracts and accounting documents must be kept for up to 10 years. If we no longer need this data to carry out 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 to lodge a complaint with a data protection supervisory authority
You have the right to complain to a data protection supervisory authority at any time.

Stand: May 2018