This Privacy Policy describes the types of information we collect from you or that you provide to us when you visit www.tamle.de (our “website”), our practices for collecting, using, protecting and disclosing this information, and the choices you have in connection with this information.

General Information
a) What law applies?
In principle, we will only use your Personal Data in accordance with the applicable data protection laws, in particular Germany`s Federal Data Protection Act (“BDSG”) and the General Data Protection Regulation (“GDPR”).

b) What is Personal Data?
Personal Data is any information relating to personal or material circumstances that relates to an identified or identifiable individual. This includes, for example, your name, date of birth, e-mail address, postal address, or telephone number as well as online identifiers such as your IP address.

c) What is processing?
"Processing" means any operation or set of operations which is performed upon Personal Data, whether or not by automatic means. The term is broad and covers virtually any handling of data.

d) Who is responsible for data processing?
The responsible party within the meaning of the BDSG and the GDPR is Tamle GmbH of Weser Str. 55, 12045 Berlin, Germany (“Tamle”, “we”, “us”, or “our”). If you have any questions about this Policy or our data protection practices, please contact us using our Contact Form or email us at compliance@tamle.de, call +49 17634320471 or write to us at the above address.

e) What are the legal bases of processing?
In accordance with the BDSG and GDPR, we have to have at least one of the following legal bases to process your Personal Data:

• you have given your consent,
• the data is necessary for the fulfillment of a contract / pre-contractual measures,
• the data is necessary for the fulfillment of a legal obligation or
• the data is necessary to protect our legitimate interests, provided that your interests are not overridden.

Data we collect automatically
a) Log data
Each time you visit our website, our system automatically records the following data from the visiting device and stores it in a so-called log file: i) Name of the retrieved file, ii) date and time of the visit, iii) amount of data transferred, iv) message about successful retrieval, type of browser and version used, v) IP address (identification of the user's device), vi) Operating system of the visiting device, vii) Internet service provider of the visiting device, viii) website from which you access our website, and ix) which of our website pages you are accessing. The legal basis for processing is our legitimate interest.

b) Content Delivery Network
We use Shopify International Limited, 2nd Floor, 1-2 Victoria Buildings, Haddington Road, Dublin 4, Dublin Content Delivery Network (CDN) to distribute our online content. Shopify`s CDN is a network of regionally distributed servers of our technical service providers connected via the Internet. When our website is visited, your device`s browser transmits information to these service providers, which is collected in corresponding server log files. Server log files are generally anonymized and then transmitted without any personal reference. Server log files include, in particular, i) details of the browser and operating system used, ii) the previously visited pages (so-called referral URL), iii) the IP address of the device used, iv) the name of the Internet provider, as well as v) the date, time of all page views including the amount of data transmitted. The legal basis for processing is our legitimate interest.
c) Provision of the Shop
We also use the store system of Shopify, for the purpose of hosting and displaying the website and shop on the basis of processing on our behalf. All data collected on our website is processed on Shopify's servers. The legal basis for the data processing is our legitimate interest in providing an appealing website and shop.

d) Cookies
We use so-called cookies on our website. Cookies are pieces of information that are transmitted from our web server or third-party web servers to your web browser and stored there for later retrieval. Cookies may be small files or other types of information storage. There are different types of cookies: i) Essential Cookies. Essential cookies are cookies to provide a correct and user-friendly website; and ii) Non-essential Cookies. Non-essential Cookies are any cookies that do not fall within the definition of essential cookies, such as cookies used to analyses your behavior on a website (“analytical” cookies) or cookies used to display advertisements to you (“advertising” cookies). For further information on the Cookies we use, please refer to our Cookie Policy. The legal basis for processing is our legitimate interest and your consent.

e) Third-party services and content
We use content or service offers of third-party providers on the basis of our legitimate interests in order to integrate their content and services ("services").

This always requires that the third-party providers of this content are aware of the IP address of the user, as without the IP address they would not be able to send the content to their browser. The IP address is therefore necessary for the display of this content.

The following provides an overview of third-party providers and their content, together with links to their privacy policies, which contain further information on the processing of data and so-called opt-out measures, if any,

• Analytics: Google Analytics by Google LLC,
• Remarketing and Advertisement: Facebook Remarketing by Meta Platforms Inc
If you do not wish to participate in our advertising personalization or retargeting/tracking you can object to behavioral advertising at the following websites: Your Online Choices, Digital Advertising Alliance of Canada, Network Advertising Initiative, AdChoices and the European Interactive Digital Advertising Alliance (Europe only).
Data we collect directly
a) Contacting us
Personal Data is processed depending on the contact method. In addition to your name and email address, IP address or phone number, we usually collect the context of your message, which may also include certain Personal Data. The Personal Data collected when you contact us is used to process your request and the legal basis is your consent.

We are present on social media (currently Instagram) on the basis of our legitimate interest. If you contact or connect with us via social media platforms, we and the relevant social media platform are jointly responsible for the processing of your data and enter into a so-called joint controller agreement. The legal basis is our legitimate interest, your consent or, in some cases, the initiation of a contractual service, if any.

b) Order processing
When you place an order in our online shop, we store your full name, your e-mail address, your address (billing address and, if applicable, different delivery address). In order to fulfill that contract, we pass on your data to the shipping company commissioned with the delivery, insofar as this is necessary for the delivery of ordered goods. If you have given us your express consent during or after your order, we will pass on your e-mail address and telephone number to the selected shipping service provider so that they can deliver your order and contact you before delivery for the purpose of delivery notification or coordination.

c) Payment Data
If you make a purchase your payment will be processed via our payment service provider Shopify International Limited (ShopPay) and its associated Payment Methods. Payment data will solely be processed through Shopify and we have no access to any Payment Data you may submit. The legal basis for the provision of a payment system is the establishment and implementation of the user contract for the use of the service.

d) Contractual notifications and Newsletter
By making a purchase, we will need to send you because of our legal obligation an invoice and other contractual documents and for this purpose we will use your e-mail address. Equally, you may also sign up for our newsletter. Those typically include administrative information as well as service and product updates. Our newsletter is sent as part of processing on our behalf by Klaviyo to whom we pass on your e-mail address for this purpose.

e) Marketing
Insofar as you have given us your separate consent to process your data for marketing and advertising purposes, we are entitled to contact you for these purposes via the communication channels you have given your consent to.

You may give us your consent in a number of ways including by selecting a box on a form where we seek your permission to send you marketing information, or sometimes your consent is implied from your interactions or contractual relationship with us. Where your consent is implied, it is on the basis that you would have a reasonable expectation of receiving a marketing communication based on your interactions or contractual relationship with us.

Direct Marketing generally takes the form of e-mail but may also include other less traditional or emerging channels. These forms of contact will be managed by us, or by our contracted service providers. Every directly addressed marketing sent or made by us or on our behalf will include a means by which you may unsubscribe or opt out.

f) Market Research
For business reasons and in order to be able to recognize market trends, wishes of contractual partners and users, we analyze the data we have on business transactions, contracts, inquiries, etc., whereby the group of persons concerned may include contractual partners, interested parties, customers, visitors, and users of our shop.

The analyses are carried out for the purpose of business evaluations, marketing, and market research (e.g., to determine customer groups with different characteristics). The analyses serve us alone and are not disclosed externally, unless they are anonymous analyses with summarized, i.e., anonymized values. Furthermore, we take the privacy of users into consideration and process the data for analysis purposes as pseudonymously as possible and, if feasible, anonymously (e.g., as summarized data).

Principles of processing Personal Data
a) Storage and Retention
At the time of data collection, for example in the context of a contractual relationship we process and store Personal Data from you. We process and store your Personal Data only to achieve the respective processing purpose or for as long as a legal retention period exists. Once the purpose has been achieved or the retention period has expired, the corresponding data is routinely deleted.

b) Security
Our website uses SSL or TLS encryption to ensure the security of data processing and to protect the transmission of confidential content, such as orders, login data or contact requests that you send to us. We have also implemented numerous security measures (“technical and organizational measures”) for example encryption or need to know access, to ensure the most complete protection of Personal Data processed through this website.

Nevertheless, internet-based data transmissions can always have security gaps, so that absolute protection cannot be guaranteed. And databases or data sets that include Personal Data may be breached inadvertently or through wrongful intrusion. Upon becoming aware of a data breach, we will notify all affected individuals whose Personal Data may have been compromised as expeditiously as possible after which the breach was discovered.

c) Special Category Data
Unless specifically required when using our services and explicit consent is obtained for that service, we do not process special category data.

d) Minors
We do not request Personal Data from minors and children and do not knowingly collect such data or pass it on to third parties.

e) Automated decision-making
Automated decision-making is the process of making a decision by automated means without any human involvement. Automated decision-making including profiling does not take place.

f) Do Not Sell
We do not sell your Personal Data.

g) Sharing and Disclosure
We will not disclose or otherwise distribute your Personal Data to third parties unless this is i) necessary for the performance of our services including our overseas fulfillment and shipping forwards, ii) you have consented to the disclosure, iii) or if we are legally obliged to do so e.g., by court order or if this is necessary to support criminal or legal investigations or other legal investigations or other legal proceedings; or proceedings at home or abroad or to fulfill our legitimate interests.

h) International Transfer
We may transfer your Personal Data to other companies as necessary for the purposes described in this Privacy Policy. In order to provide adequate protection for your Personal Data when it is transferred, we have contractual arrangements regarding such transfers. We take all reasonable technical and organizational measures to protect the Personal Data we transfer.

Your Rights and Privileges
a) Privacy rights
Under the BDSG and GDPR, you have the following rights:
• Right to information
• Right to rectification
• Right to object to processing
• Right to deletion
• Right to data portability
• Right of objection
• Right to withdraw consent
• Right to complain to a supervisory authority
• Right not to be subject to a decision based solely on automated processing.

If you have any questions about the nature of the Personal Data we hold about you, or if you wish to exercise any of your rights, please contact us.

b) Updating your information
If you believe that the information, we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing, please do so by contacting us.

c) Withdrawing your consent
You can revoke consents you have given at any time by contacting us. The legality of the data processing carried out until the revocation remains unaffected by the revocation.

d) Access Request
In the event that you wish to make a Data Subject Access Request, you may inform us in writing of the same. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days, we will tell you why and when we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we will tell you why.

e) Complaint to a supervisory authority
You have the right to complain about our processing of Personal Data to a supervisory authority responsible for data protection. The Berlin DPA (Berliner Beauftragte für Datenschutz und Informationsfreiheit) is the state Data Protection Authority for the state of Berlin. The Berlin DPA`s contact details can be found on www.datenschutz-berlin.de.

Changes and Questions
We may update this Privacy Policy from time to time. If we make changes to this Privacy Policy or materially change our use of your Personal Data, we will revise this Privacy Policy accordingly and also change the effective date at the end of this section. We encourage you to periodically review this Privacy Policy to be informed of how we use and protect your Personal Data. If you would like to contact us regarding our privacy practices for any reason, please do so using the details provided above.

Effective Date
Friday, 28 April 2023