Privacy Policy

1) Information about the collection of personal data and contact details of the controller 1.1 We are pleased that you have visited our website and thank you for your interest. In the following we will inform you about how your personal data is handled when you use our website. Personal data is all data with which you can be personally identified. 1.2 The controller for data processing on this website within the meaning of the General Data Protection Regulation (GDPR) is Michael Wiese, Am Werder 17, 21335 Lüneburg, Germany. Tel.: 49 (0) 163-6397738, Email: michael@full-circle.de. The controller is the natural or legal person who alone or jointly with others decides on the purposes and means of processing personal data. 1.3 For security reasons and to protect the transmission of personal data and other confidential content (e.g. orders or inquiries to the controller), this website uses SSL or TLS encryption. You can recognize an encrypted connection by the string “https://” and the lock symbol in your browser line.

2) Data collection when visiting our website If you simply use our website for information purposes, i.e. if you do not register or otherwise provide us with information, we only collect data that your browser transmits to our server (so-called “server log files”). When you access our website, we collect the following data, which is technically necessary for us to display the website to you: – The website you visited – Date and time of access – Amount of data sent in bytes – Source/reference from which you accessed the page – Browser used – Operating system used – IP address used (if applicable: in anonymized form) Processing is carried out in accordance with Art. 6 (1) (f) GDPR on the basis of our legitimate interest in improving the stability and functionality of our website. The data will not be passed on or used for any other purpose. However, we reserve the right to subsequently check the server log files if there are concrete indications of illegal use.

3) Cookies In order to make visiting our website more attractive and to enable the use of certain functions, we use so-called cookies on various pages. These are small text files that are stored on your device. Some of the cookies we use are deleted after the end of the browser session, i.e. after you close your browser (so-called session cookies). Other cookies remain on your device and enable your browser to be recognized on your next visit (so-called persistent cookies). If cookies are set, they collect and process certain user information to an individual extent, such as browser and location data as well as IP address values. Persistent cookies are automatically deleted after a specified period of time, which can vary depending on the cookie. You can find out how long cookies are stored for in the overview of your web browser's cookie settings. Cookies are sometimes used to simplify the ordering process by saving settings (e.g. remembering the contents of a virtual shopping cart for a later visit to the website). If personal data is also processed through individual cookies used by us, the processing is carried out in accordance with Art. 6 (1) (b) GDPR either to execute the contract, in accordance with Art. 6 (1) (a) GDPR in the case of consent given, or in accordance with Art. 6 (1) (f) GDPR to protect our legitimate interests in the best possible functionality of the website and a customer-friendly and effective design of the site visit. Please note that you can set your browser so that you are informed about the setting of cookies and can decide individually whether to accept them or exclude the acceptance of cookies for certain cases or in general. Each browser differs in the way it manages cookie settings. This is described in the help menu of each browser, which explains how you can change your cookie settings. You can find these for the respective browsers under the following links: Internet Explorer: https://support.microsoft.com/de-de/help/17442/windows-internet-explorer-delete-manage-cookies Firefox: https://support.mozilla.org/de/kb/cookies-erlauben-und-ablehnen Chrome: https://support.google.com/chrome/answer/95647?hl=de&hlrm=en Safari: https://support.apple.com/de-de/guide/safari/sfri11471/mac Opera: https://help.opera.com/de/latest/web-preferences/#cookies Please note that if you do not accept cookies, the functionality of our website may be limited.

4) Contacting us When you contact us (e.g. via contact form or email), personal data is collected. The data collected when you use a contact form can be seen in the respective contact form. This data is stored and used solely for the purpose of answering your query or for contacting you and the associated technical administration. The legal basis for processing this data is our legitimate interest in answering your query in accordance with Art. 6 (1) (f) GDPR. If your contact is aimed at concluding a contract, the additional legal basis for processing is Art. 6 (1) (b) GDPR. Your data will be deleted after your query has been finally processed. This is the case if it can be inferred from the circumstances that the matter in question has been conclusively clarified and provided that there are no statutory retention periods to the contrary.

5) Data processing when opening a customer account and for contract processing In accordance with Art. 6 (1) (b) GDPR, personal data will continue to be collected and processed if you provide it to us to execute a contract or when opening a customer account. Which data is collected can be seen from the respective input forms. You can delete your customer account at any time and can do so by sending a message to the above-mentioned address of the person responsible. We store and use the data you provide to process the contract. After the contract has been fully processed or your customer account has been deleted, your data will be blocked with regard to retention periods under tax and commercial law and deleted after these periods have expired, unless you have expressly consented to further use of your data or we have reserved the right to further use of the data as permitted by law.

6) Use of customer data for direct advertising Sending the email newsletter to existing customers If you have provided us with your email address when purchasing goods or services, we reserve the right to regularly send you offers for goods or services from our range that are similar to those you have already purchased. According to Section 7 (3) of the Unfair Competition Act (UWG), we do not need to obtain your separate consent for this. In this respect, data processing is carried out solely on the basis of our legitimate interest in personalized direct advertising in accordance with Art. 6 (1) (f) GDPR. If you initially objected to the use of your email address for this purpose, we will not send you any emails. You are entitled to object to the use of your email address for the aforementioned advertising purpose at any time with effect for the future by notifying the person responsible named at the beginning. You will only incur transmission costs according to the basic rates. Once your objection has been received, the use of your email address for advertising purposes will be stopped immediately.

7) Data processing for order processing 7.1 To process your order, we work with the following service provider(s), who support us in whole or in part in the execution of concluded contracts. Certain personal data will be transmitted to these service providers in accordance with the following information. The personal data we collect will be passed on to the transport company commissioned with the delivery as part of the contract processing, insofar as this is necessary for the delivery of the goods. We will pass on your payment details to the commissioned credit institution as part of the payment processing, insofar as this is necessary for the payment processing. If payment service providers are used, we will inform you explicitly about this below. The legal basis for the transfer of data is Art. 6 (1) (b) GDPR. 7.2 Transfer of personal data to shipping service providers - DHL If the goods are delivered by the transport service provider DHL (DHL Paket GmbH, Sträßchensweg 10, 53113 Bonn), we will pass on your email address to DHL in accordance with Art. 6 (1) (a) GDPR before delivery of the goods for the purpose of coordinating a delivery date or to provide delivery notification, provided that you have given your express consent to this during the ordering process. Otherwise, for the purpose of delivery in accordance with Art. 6 (1) (b) GDPR, we will only pass on the name of the recipient and the delivery address to DHL. This data will only be passed on if this is necessary for the delivery of the goods. In this case, prior coordination of the delivery date with DHL or delivery notification is not possible. Consent can be revoked at any time with future effect by notifying the person responsible named above or the transport service provider DHL. – Hermes If the goods are delivered by the transport service provider Hermes (Hermes Logistik Gruppe Deutschland GmbH, Essener Straße 89, 22419 Hamburg), we will pass on your email address to Hermes before delivery of the goods in accordance with Art. 6 (1) (a) GDPR for the purpose of coordinating a delivery date or to provide delivery notification, provided that you have given your express consent to this during the ordering process. Otherwise, for the purpose of delivery in accordance with Art. 6 (1) (b) GDPR, we will only pass on the name of the recipient and the delivery address to Hermes. This information will only be passed on if this is necessary for the delivery of the goods. In this case, prior coordination of the delivery date with Hermes or the transmission of status information on the shipment delivery is not possible. Consent can be revoked at any time with future effect by notifying the person responsible named above or the transport service provider Hermes.

8) Tools and Miscellaneous 8.1 sevDesk For accounting purposes, we use the sevDesk service, a cloud-based accounting software from sevDesk GmbH, Hauptstraße 115, 77652 Offenburg. SevDesk processes incoming and outgoing invoices, as well as, if applicable, our company's bank transactions, in order to automatically record invoices, match them to transactions, and use these to create financial accounting in a semi-automated process. If personal data is also processed, the processing is carried out in accordance with Art. 6 (1) (f) GDPR on the basis of our legitimate interest in the efficient organization and documentation of our business transactions. Further information about sevDesk GmbH, the automated processing of data, and the data protection regulations can be found at https://sevdesk.de/sicherheit-datenschutz/ 8.2 Google Customer Reviews (formerly Google Certified Retailer Program) We work with Google as part of the “Google Customer Reviews” program. The provider is Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland (“Google”). This program gives us the opportunity to collect customer reviews from users of our website. After making a purchase on our website, you will be asked whether you would like to participate in an email survey from Google. If you give your consent in accordance with Art. 6 (1) (a) GDPR, we will transmit your email address to Google. You will receive an email from Google Customer Reviews asking you to rate your purchasing experience on our website. The rating you submit will then be summarized with our other reviews and displayed in our Google Customer Reviews logo and in our Merchant Center dashboard. Your rating will also be used for Google Seller Ratings. Using Google Customer Reviews may also result in the transmission of personal data to the servers of Google LLC in the USA. You can revoke your consent at any time by sending a message to the data controller or to Google. Further information on Google's data protection in connection with the Google Customer Reviews program can be found at the following link: https://support.google.com/merchants/answer/7188525?hl=de Further information on the data protection of Google Seller Reviews can be found at this link: https://support.google.com/google-ads/answer/2375474

9) Rights of the data subject 9.1 Applicable data protection law grants you comprehensive data subject rights (rights to information and intervention) vis-à-vis the controller with regard to the processing of your personal data, about which we will inform you below: - Right to information in accordance with Art. 15 GDPR: In particular, you have the right to information about your personal data processed by us, the processing purposes, the categories of personal data processed, the recipients or categories of recipients to whom your data have been or will be disclosed, the planned storage period or the criteria for determining the storage period, the existence of a right to rectification, erasure, restriction of processing, objection to processing, complaint to a supervisory authority, the origin of your data if it was not collected from you by us, the existence of automated decision-making including profiling and, if applicable, meaningful information about the logic involved and the scope and intended effects of such processing concerning you, as well as your right to be informed of the guarantees in place pursuant to Art. 46 GDPR when your data is transferred to third countries; – Right to rectification pursuant to Art. 16 GDPR: You have the right to have any inaccurate data concerning you rectified without undue delay and/or to have any incomplete data stored by us completed; – Right to erasure pursuant to Art. 17 GDPR: You have the right to request the erasure of your personal data if the requirements of Art. 17 (1) GDPR are met. However, this right does not apply if processing is necessary to exercise the right to freedom of expression and information, to fulfill a legal obligation, for reasons of public interest, or to assert, exercise, or defend legal claims; – Right to restriction of processing pursuant to Art. 18 GDPR: You have the right to request that the processing of your personal data be restricted as long as the accuracy of your data, which you dispute, is being verified; if you refuse to delete your data due to inadmissible data processing and instead request that the processing of your data be restricted; if you need your data to assert, exercise or defend legal claims after we no longer need this data after the purpose has been achieved or if you have lodged an objection for reasons related to your particular situation, as long as it has not yet been determined whether our legitimate reasons prevail; – Right to information pursuant to Art. 19 GDPR: If you have asserted your right to rectification, erasure or restriction of processing vis-à-vis the controller, the controller is obliged to inform all recipients to whom the personal data concerning you was disclosed of this rectification, erasure or restriction of processing, unless doing so proves impossible or involves disproportionate effort. You have the right to be informed about these recipients. – Right to data portability pursuant to Art. 20 GDPR: You have the right to receive the personal data you have provided to us in a structured, common, and machine-readable format or to request that it be transmitted to another controller, where technically feasible; – Right to revoke consent granted pursuant to Art. 7 (3) GDPR: You have the right to revoke your consent to the processing of data at any time with future effect. In the event of revocation, we will delete the data concerned immediately, unless further processing can be based on a legal basis for processing without consent. The revocation of consent does not affect the legality of the processing carried out on the basis of the consent up to the time of revocation; – Right to lodge a complaint pursuant to Art. 77 GDPR: If you believe that the processing of personal data concerning you violates the GDPR, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your residence, place of work, or place of the alleged violation, without prejudice to any other administrative or judicial remedy. 9.2 Right to object: If we process your personal data based on our overriding legitimate interest as part of a balancing of interests, you have the right to object to this processing at any time, with effect for the future, for reasons arising from your particular situation. If you exercise your right of objection, we will stop processing the data concerned. However, we reserve the right to continue processing if we can demonstrate compelling legitimate grounds for the processing that override your interests, fundamental rights, and freedoms, or if the processing serves to assert, exercise, or defend legal claims. If your personal data is processed by us for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing purposes. You can exercise your right of objection as described above. If you exercise your right of objection, we will stop processing the data concerned for direct marketing purposes.

10) Duration of storage of personal data The duration of storage of personal data is determined by the respective legal basis, the purpose of processing and - if applicable - also by the respective statutory retention period (e.g. retention periods under commercial and tax law). When personal data is processed on the basis of express consent in accordance with Art. 6 (1) (a) GDPR, this data will be stored until the data subject revokes their consent. If statutory retention periods exist for data that is processed within the framework of legal transactions or quasi-legal obligations on the basis of Art. 6 (1) (b) GDPR, this data will be routinely deleted after the retention periods have expired, provided that it is no longer required to fulfill or initiate a contract and/or we no longer have a legitimate interest in continuing to store it. When personal data is processed on the basis of Art. 6 (1) (f) GDPR, this data will be stored until the data subject exercises his or her right of objection pursuant to Art. 21 (1) GDPR, unless we can demonstrate compelling legitimate grounds for the processing which outweigh the interests, rights and freedoms of the data subject, or the processing serves to assert, exercise or defend legal claims. When personal data is processed for the purpose of direct marketing on the basis of Art. 6 (1) (f) GDPR, this data will be stored until the data subject exercises his or her right of objection pursuant to Art. 21 (2) GDPR. Unless the other information in this declaration on specific processing situations indicates otherwise, stored personal data will be deleted when it is no longer necessary for the purposes for which it was collected or otherwise processed.