Privacy policy

Privacy Policy

Date: [November 27, 2022]

1. Information about the collection of personal data

1.1 Personal data

In the following, we will inform you about the processing of personal data when using our website. Personal data are all data that may relate to you personally, such as name, address, e-mail address, user behaviour. In this way, we would like to inform you about our processing procedures and at the same time comply with our legal obligations, in particular those of the EU General Data Protection Regulation (GDPR).

1.2 Data Controller

According to the data controller of Art. 4 (7) GDPR is [company name: 91sneakers LLC, company contact: [email protected]].

2. Processing of personal data when visiting our website

When using this website for informational purposes, i.e. only viewing it without registering and without providing us with any other information, we process the personal data that your browser transmits to our server. The data described below are technically necessary for us to present our website to you and to ensure stability and security and must therefore be processed by us. The legal basis is art. 6 (1)f GDPR:

(1) IP address

(B) Date and time of request

(C) Request content (accessed pages)

(D) Amount of data transferred in each case

(E) Browser

3. Further functions and offers on our website

3.1 Overview of various offers

In addition to the purely informational use of our website, we offer various services that may be of interest to you (e.g. registering an account, purchasing goods), we also use other functions to facilitate sales (e.g. payment method selection) and to analyze or market our , which are described in more detail in Sections 4 and 5 below. For this purpose, you generally have to provide further personal data and/or we process such further data for us to perform the respective service. The above data processing principles apply to all data processing purposes described here.

3.2 Use of external service providers

In some cases, we use external service providers to process your data (e.g. payment service providers, shipping companies, see sections 5 and 6 below for more information on these). These service providers are carefully selected by us, bound by our instructions and regularly monitored.

3.3 Further Third Party Involvement

Furthermore, if we participate in promotions, competitions, contracts or similar services with our partners, we may pass on your personal data to third parties not mentioned in this privacy policy. Depending on the service, your data may also be collected by the partner under their own responsibility. You will receive more detailed information when you provide the data or in the description of the corresponding offer.

3.4 Third parties outside the EEA

If our service provider or partner is located in a country outside the European Economic Area (EEA), we will inform you of the consequences of this in the quotation description.

4. Processing of personal data when you contact us or register an account with us

When you contact us by e-mail or contact form, the data you provide (your e-mail address, name and telephone number, if applicable) will be stored by us in order to answer your question. When you register for a customer account with us, we only collect information that you voluntarily share with us. This data may include, for example:

(A) Your first and last name and, as the case may be, your title or username

(B) Login data: your e-mail address and a password of your own choosing

(C) Your contact details, such as your name, postal address, telephone number, fax number, email address

(D) any further information you may share with us about yourself and your interests

5. Processing of personal data when you shop with us

5.1 Shopping information

If you order an item from our online store, we collect your shopping data. Depending on the purchase type and processing status, Purchase Data may include the following information:

(A) Details of purchased items (name, price, model, etc.)

(B) order number

(C) Shipping and billing addresses

(D) Delivery and payment status, such as "Completed" or "Dispatched"

(E) Purchase-related messages and communications (such as complaints and messages to customer service)

(F) return status, eg "in progress"

(G) Information about service providers (such as shipment numbers for parcel services)

5.2 Payment Details

We offer you a variety of payment methods - especially [credit card], [PayPal]. We collect the payment details you share to execute the payment. We receive further payment details from external payment service providers and credit bureaus with whom we cooperate when executing payments and conducting credit checks. We only forward to our payment service providers the information necessary to process the payment.


Payment details include:

(A) Billing addresses

(B) Preferred payment method

(C) IBAN and BIC or account number and sort code

(D) Credit card details

The payment details also include other information directly connected to payment processing and credit checking. This applies, for example, to information which external payment service providers use for identification such as your PayPal ID if you are paying with PayPal.

5.3 Transfer of data on outstanding debts to collection service providers

In the event that outstanding invoices are not settled despite repeated reminders, we may transfer the data required to commission a collection service provider to a collection service provider for the purpose of collecting the debt. Alternatively, we may sell the debt to a collection service provider which is then able to file a claim in its own name. The agencies we charge with collection services are the following [Please fill in the information of the debt collection service provider you cooperate with, if not, delete this paragraph]

Legal basis: The legal basis for transferring data within the framework of fiduciary collection services is Article 6 (1) b GDPR; data is transferred within the framework of selling debt on the basis of Article 6 (1) f GDPR.

6. Cookie

6.1 General information about cookies

We may use cookies, tags, web pixels, and similar technologies to automatically collect information on our Services. Cookies or tags are bits of code that allow our technology partners to collect information that usually does not directly identify you. If required by law, we will request your consent before using cookies or other tracking technologies. Information within this section describes our use of cookies and your ability to control the use of cookies for advertising-related purposes. As described below, we will not use cookies or similar tracking technologies that process your personal data, unless they are Strictly Necessary Cookies, or you opt-in, i.e. consent, by using the cookie banner or consent manager found on our Site. You may withdraw your consent or update your preferences at any time by clicking the “Manage Cookies” link within the website footer.

6.2 Cookies.

Cookies are small web files that a site or its provider transfers to your device’s hard drive through your web browser that enables the site’s or provider’s system to recognize your browser and remember certain information.

Generally, we use first-party and third-party cookies for the following purposes: to make our Services function properly; to provide a secure browsing experience during your use of our Services; to collect passive information about your use of our Services; to measure how you interact with our marketing campaigns; to help us improve our Services; and to remember your preferences for your convenience.

We use the following types of cookies on our Services:

Strictly Necessary Cookies. These cookies are essential because they enable you to use our Services. For example, strictly necessary cookies allow you to access secure areas on our Services. Without these cookies, some services cannot be provided. These cookies do not gather information about you for marketing purposes. This category of cookies is essential for our Services to work and they cannot be disabled.

Functional Cookies. We use functional cookies to remember your choices so we can tailor our Services to provide you with enhanced features and personalized content. For example, these cookies can be used to remember your name or preferences on our Services. We do not use functional cookies to target you with online marketing. While these cookies can be disabled, this may result in less functionality during your use of our Services.

Performance or Analytic Cookies. These cookies collect passive information about how you use our Services, including webpages you visit and links you click. We use the information collected by such cookies to improve and optimize our Services. We do not use these cookies to target you with online marketing. You can disable these cookies as set forth below.

Advertising or Targeting Cookies. These cookies are used to make advertising messages more relevant to you. They perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly displayed for advertisers, and in some cases selecting advertisements that are based on your interests. Our third-party advertising partners may use these cookies to build a profile of your interests and deliver relevant advertising on other sites. You may disable the use of these cookies as set forth below.

6.3 Your Choices

You can manage browser cookies through your browser settings. The 'Help' feature on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, how to block cookies, and when cookies will expire. If you block all cookies on your browser, neither we nor third parties will transfer cookies to your browser. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some features and services may not work.

6.4 Web Pixels .

To see how successfully our marketing campaigns or other goals of the Services are performing we sometimes use conversion pixels, which fire a short line of code to tell us when you have clicked on a particular button or reached a particular page (e.g. a thank you page once you have completed the procedure for subscribing to one of our services or have completed one of our forms). We also use web pixels to analyze usage patterns on our Services. The use of a pixel allows us to record that a particular device, browser, or application has visited a particular webpage.

6.5 Analytics.

We may use third-party service providers to monitor and analyze the use of our Services. Presently, we use Google Analytics . Google Analytics is a web analytics service that tracks and reports Site traffic. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en . Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics, available at: https://tools.google.com/dlpage/gaoptout .

6.6 Behavioral Remarketing

We also use remarketing services to advertise on third-party websites to you after you visited our Services. For this purpose, visitors are grouped by certain actions on our Services, e.g., by duration of a visit. This enables us to understand your preferences and to show you personalized advertising even if you are currently surfing on another website that also participates in the Google advertising network.

We use the following tools and services for these purposes:

Google Ads remarketing service is provided by Google. You can opt-out of this by visiting the Google Ads Settings page: https://www.google.com/settings/ads .

If Google Ads is structured to collect personal data, the data controller will be Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland.

Bing Ads is a service operated by Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland. Please read Microsoft’s privacy statement for more information on how Microsoft processes your information https://privacy.microsoft.com/en-US/ . When you access our Site via advertisements on Bing Ads, a cookie is set on your computer. In addition, a Universal Event Tracking tag is integrated on our Site. This is a code that, in combination with the cookie, stores data about the use of the Site, e.g. length of time spent on the Site, areas accessed, and ads used to reach the Site. In addition, Microsoft may track your usage patterns across multiple of your electronic devices through so-called cross-device tracking. The information collected is transferred to a Microsoft server in the United States. If Bing Ads is structured to collect personal data, the cookie banner on our Services will provide you the opportunity to consent to Bing Ads.

Facebook Ads. Using Facebook Business Tools , we may display interest-based ads to you when using Facebook. To modify your preferences or turn off personalization for ads served by Facebook, you can visit Facebook's Ad Preferences in addition to the Your Choices section below. We do not share any of your personal information with Facebook. We may also show ads to audiences that share similar characteristics as you. To do so, a list of email addresses is irreversibly encrypted through hashing and uploaded or transmitted from our site, and Facebook matches the hashed data against its own users, generating a lookalike audience and deleting the uploaded list. We do not have access to the identity of anybody in the “lookalike” audience, unless they choose to click on one of our advertisements.

6.7 Other Tracking Technologies .

We may also use Tracking Technologies to collect "clickstream" data, such as the domain name of the service providing you with Internet access, your device type, IP address used to connect your computer to the Internet, your browser type and version, operating system and platform, the average time spent on our Site, webpages viewed, content searched for, access times and other relevant statistics, and assign unique identifiers to the device or other credentials you use to access the Site for the same purposes.

Pages of our Site may also use Java scripts, which are code snippets embedded in various parts of websites and applications that facilitate a variety of operations including accelerating the refresh speed of certain functionality or monitoring usage of various online components; entity tags, which are HTTP code mechanisms that allow portions of websites to be stored or “cached” within your browser to accelerate website performance; and HTML5 local storage, which allows data from websites to be stored or “cached” within your browser to store and retrieve data in HTML5 pages when the website is revisited.

6.8 Do Not Track.

Certain Internet browsers (such as Internet Explorer, Firefox and Safari) have the ability to transmit a "Do Not Track" or "DNT" signal. Because a uniform standard for "DNT" signals has not yet been adopted, our site does not currently process or respond to "DNT" signals.

6.9 Location Information.

You can adjust your device settings so that no information about your physical location is sent to us or third parties by (a) disabling location services in your device settings; (b) by changing your mobile device or browser settings to Preferences and permissions related to denying certain websites or mobile applications access to location information

7. Data transfer to third parties

7.1 Transfer only as permitted by law

We will only forward your data to the extent permitted by German or European law. We cooperate particularly closely with certain service providers, e.g. in the field of customer service (e.g. hotline service providers), technical service providers (e.g. operating computer centers) or logistics companies (e.g. postal companies, e.g. [YT Logistics]). These service providers generally only process your data on our behalf under special conditions. When we use them to process an order, the service provider can only access your data to the extent and for the time period necessary to provide the relevant service. If you shop with one of our partners, we will forward certain shopping data about you to the partner (such as your name and delivery address) so that the partner can send you the ordered goods.

7.3 Technical service provider

We work with technology service providers to be able to provide our services. If they process your data outside the EU, this may mean that your data is transferred to countries with lower data protection standards than the EU. In such cases, we will ensure that the relevant service provider guarantees an equivalent level of data protection either contractually or otherwise.

7.4 Payment service providers and credit institutions

We offer different payment methods such as prepayment, credit card payment, PayPal payment and payment by invoice. For this purpose, payment data can be transmitted to payment service providers with whom we cooperate.

7.5 Shipping company

(A) We cooperate with external shipping companies (such as [YT logistics company www.yunexpress.cn]) to deliver orders. These shipping companies receive the following data for the execution of the relevant order:

(B) your name

(C) Your shipping address

(D) If applicable, your postcode (if you wish to have your order delivered to a DHL packing station)]

(E) Your email address (if applicable) (if the carrier wishes to notify you of provisional delivery dates by email)

7.6 Authorities and other third parties

In the event of an official or court decision or for prosecution purposes, we will, if necessary, forward your data to the prosecution or other third parties.

8. Retention and deletion of data

We will store your personal data for as long as necessary for the purposes specified in this privacy statement, in particular to fulfill our contractual and legal obligations. We may also store your personal data for other purposes, including the defense of legal claims, if and as long as we are permitted by law to store your personal data for a particular purpose.

If you close your customer account, we will delete all data we have stored about you. If complete deletion of your data is not possible or necessary for legal reasons, the relevant data will be blocked for further processing. If data is blocked, technical and organizational measures will be used to ensure that only a limited number of employees have access to the relevant data, on a need-to-know basis and only for specific purposes (e.g. in the case of tax audits). Blocking will occur because, for example, in the following situations:

(A) Your order and payment details and possibly other details are generally subject to various legal retention obligations, such as those in Handelsgesetzbuch (HGB - Commercial Code) and Abgabenordnung (AO - Tax Law). We are required by law to retain this data for up to ten years for tax audits and financial audits. Only then can we finally delete the data in question.

(B) Even if your data is not subject to any legal retention obligations, where legally permitted, we may avoid immediate deletion and instead perform an initial block. This applies in particular in cases where we may require the relevant data for further contractual processing or for prosecution or legal defense (e.g. in the case of a complaint). The decisive criterion for the duration of the blockade is the statutory limitation period. The relevant data will eventually be deleted after the expiry of the relevant limitation period.

If the data are anonymous or pseudonymized, exemption from erasure is permitted by law and erasure would preclude or substantially hinder processing for scientific research or statistical purposes.

9. How is my personal data protected?

We use technical and organizational measures to protect our systems. Regarding your order and your customer login, we use SSL encryption (Secure Sockets Layer) to transmit your personal data securely.

10. Your rights

10.1 Your rights against us as a data controller

As the data controller of personal data concerning you, you have the following rights against us:

(A) the right to know,

(B) the right to rectification or deletion,

(C) the right to restrict processing,

(D) the right to object to processing,

(E) Right to data portability.

(F) Right to withdraw consent (if consent is the basis for data processing).

10.2 Information requests

To ensure that your data are not disclosed to third parties during the information request process, please include sufficient identification with your request.

10.3 Withdrawal of Consent.

If you have given your consent to the processing of your data, you can withdraw this consent at any time. Such withdrawal affects the consent to process your personal data after you have indicated to us. The processing of your data remains unaffected until your withdrawal.

10.4 Balance of interests to handle objections

(A) If we process your personal data on the basis of a balance of interests, you may object to the processing. This is the case if processing is not necessary, in particular for the fulfillment of a contract with you, which we indicate in each case in the description of the functions below. When making such an objection, we will ask you to explain why we should not process your personal data in the way we have already done. If you object, we will review the situation and stop or adjust data processing, or we will show you compelling legitimate grounds for us to continue processing.

(B) Of course, you can object to the processing of your personal data for advertising and data analysis purposes at any time. The best way to exercise your advertising objection is to contact us using the contact details provided above.

You also have the right to complain to a data protection supervisory authority about our processing of your personal data. The authority of the supervisory authority depends on the location of the data controller. However, you may contact any data protection authority in any member state of the European Union, in particular the data protection authority of your place of residence, who will forward your complaint to the competent authority.

11. Changes to this Privacy Policy

Further improvements to our website or changes in legal or regulatory requirements may require changes to this privacy statement. Therefore, we encourage you to re-read this Privacy Statement from time to time.