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Privacy Policy

This privacy policy gives an overview of the processing of your data at zLabels. It applies to all websites and other services and benefits provided by zLabels.

How to read this privacy policy: There are several ways to read this privacy policy. Firstly, this section contains some basic information. After that, we have arranged the privacy policy into relevant topics for you and divided them into individual chapters accordingly. So if you are already an expert at this, you can jump straight to an individual chapter.
We have done without cross-references as often as possible. So no matter what chapter you are looking at, it will give you all the information you need and explain it coherently. However, if you read this privacy policy from the beginning to end, you may notice repeated text.

Which services and offers this privacy policy applies to: This privacy policy therefore applies to all services and benefits that we offer to our customers and suppliers in Europe, regardless of whether they are provided through a website, by phone, at events or through other channels.

What information is covered in this privacy policy:

  • What data zLabels stores.
  • What we do with this data and why it is needed.
  • What your data protection rights and options are.
  • What technologies and data we use for advertising.

If you have a question about this privacy policy or about data protection at zLabels in general, you can always contact our Data Protection Officer at datenschutz@zalando.de.

What data does zLabels process?

zLabels deals with the design, purchase and resale of clothing. The data used for this is essentially not personal. zLabels also has no contractual relationships with end customers. We only receive data collected during your interaction with our websites or from your personal contact with our employees. For example, it may be information about which device you are using, or about your contact details.

When we talk about “your data,” we mean personal data. This is any information that we could use to identify you directly or in combination with other information. Examples: your name, your telephone number, your customer number, order numbers or your e-mail address. Any information that we cannot use to identify you, even when combined with other information, is considered non-personal data. Non-personal data is also called anonymous data. When we combine your personal data with anonymous data, all data in that data set will be considered personal data. If we delete the personal data from any information or data set relating to you, then the remaining data in that data set will no longer be considered personal data. This procedure is called anonymisation. In principle: if we ask you to provide certain personal information, you can of course decline to do so. You decide what information you give us. However, we may not be able to provide you with your desired services (or not optimally). This may be the case for e.g. the presentation of the website.

1.1 Contact details

If you contact us, e.g. in order to express your interest, we collect your contact details. Your contact details may, depending on how you contact us (e.g. by contact form, by phone or e-mail), include your name, company affiliation, postal addresses, telephone numbers, fax numbers, e-mail addresses, and similar contact details.

1.2 Conversation contents, contact forms

When you communicate with us or other users by telephone, post, social media, contact forms or in other ways, we collect the content of your messages.
If you contact us via a contact form, we collect the information provided by you on the form in addition to your contact details.

1.3 Social network data

zLabels also uses the services of social networks such as Facebook for its public relations work. We use these popular platforms to provide you with additional information options in addition to our own communication channels. Please note, however, that we have no control over the social networks’ terms of use or the services they offer, and have limited control over their data processing. We therefore ask you to carefully check what personal data you share with us through social media. We cannot influence the behaviour of the social network operators, other users or third parties that may collaborate with the social network operators or use their services.
By the way, we do not receive any data that could be used to identify or contact you from the social network providers without your consent. For more information, please refer to each provider’s terms of use and privacy policy.

1.4 Applications

The Zalando Group’s companies use Zalando SE’s central Zalando application management system for receiving and processing applications. The Zalando application management system’s web portal can be reached at: https://jobs.zalando.com/. The Zalando application management system has service-specific data protection information that you can access here: https://jobs.zalando.com/en/privacy-policy/.

1.5 Device and access data

When using online services, it is inevitable that technical data will be generated and processed in order to provide the features and content offered and to display them on your device. We call this data “device and access data”. Device and access data is generated during each use of an online service. It does not matter who the provider is. Device and access data therefore arises, for example, when using:

  • websites
  • location-based services

Device and access data includes the following categories:

  • general device information, such as device type, version of the operating system, configuration settings (e.g., language settings, system permissions), internet connection information (e.g., mobile network name, connection speed).
  • identification data (IDs), such as session IDs, cookie IDs, unique device ID numbers (e.g., Google Advertising ID, Apple Ad ID), third-party account IDs (if you use social plug-ins), and other common internet technologies used to recognise your web browser or device.
  • access data that is transmitted automatically by web browsers every time you access the web server and databases online (as part of so-called HTTP requests). This is standardised information about the requested content (such as the name and type of file being accessed) as well as further information about server access (such as e.g. transmitted data volume and error codes) to your device (e.g. device type, operating system, software versions, device IDs, IP addresses, the previously visited page and the time of access).

2. What does zLabels use my data for?

zLabels processes your data in compliance with all applicable data protection laws. Of course, we observe the principles of data protection law for processing personal data. Therefore, we only process your data for the purposes described in this privacy policy or communicated to you when the data was collected. These primarily include marketing for our services. In this chapter, we also explain the legal basis on which we process data for each purpose. Depending on which legal basis we process your data, you may be entitled to special data protection rights in addition to your existing data protection rights such as the right to information. For example, in some cases, you have the right to object to the processing of your data.

2.1 Advertising

We use your data for advertising purposes, including in the context of data analysis. In particular, our purposes are as follows: Finding out how our services are used (usage analysis). Depending on the purpose, we use the data stored by us for data analyses. We process your data on the basis of a balance of interests to protect our legitimate interests. zLabels’ legitimate interest in the processing of data results from the respective purposes and is, unless otherwise stated, of a competitive and economic nature. Legal basis Insofar as the data processing for the purposes described above takes place with your consent, the legal basis is Article 6 (1) (a) GDPR (Consent). In addition, data processing takes place on the basis of Article 6 (1) (f) GDPR, the legitimate interests being in the above-mentioned purposes. You can disable the processing of your data for personalised advertising and usage analysis at any time. If you click on the following link, an opt-out cookie will be set that will prevent future collection of your data when visiting this website: http://tools.google.com/dlpage/gaoptout

2.2 Application process

Purposes are: Filling specific job positions Inclusion in the talent pool so that we can contact you in the event of suitable vacancies in the future. Legal bases: Insofar as the data processing for the purposes described above takes place with your consent, the legal basis is Article 6 (1) (a) GDPR (Consent). In addition, data processing takes place on the basis of Article 6 (1) (f) GDPR, the legitimate interests being in the above-mentioned purposes. 2.3 Based on your consent If you have given us consent to process your personal data, your consent (Article 6 (1) (a) GDPR) is the primary basis for our data processing. What data we process based on your consent depends on the purpose of your consent. Typical purposes include: The entry of data in contact forms. The transmission of your data to third parties or to a country outside the European Union. Withdrawal information You may withdraw your previously granted consent at any time with effect for the future, e.g. by mail, letter or fax.

2.4 Other purposes

If data protection law permits, we may also use your information for new purposes without your consent, such as conducting data analysis and developing our services and content. This may only be carried out if the new purposes for which the data is to be used were not yet established or foreseeable when the data in question was collected, and if the new purposes are compatible with those purposes for which the data was originally collected. For example, new legal or technical developments and innovative business models and services may lead to new processing purposes.

3. Information about websites

We use your data for the provision of the zLabels websites. In addition to the device and access data associated with each use of these services, the nature of the data processed and the purposes of processing will depend in particular on how you use the features and services provided through our services. In addition, we use the data arising from the use of our services to find out how our online offer is used.

3.1 Provider

The websites’ provider is zLabels GmbH, Neue Bahnhofstrasse 11-17, 10245 Berlin, Germany.

3.2 What data is collected?

In principle, we collect all data that you provide us directly via our services.

3.2.1 Device and access data

Each access to our servers and databases causes device and access data to be logged in so-called server log files. The IP address contained therein will be anonymised at the end of the respective access at short notice, as soon as its storage is no longer necessary to maintain the functionality of the respective website. If available and enabled on your device, we will also collect a device-specific identification number (e.g., a so-called “Advertising ID” if you are using an Android device or “Ad-ID” if you are using an Apple device). This device identifier is issued by the manufacturer of your device’s operating system and can be read by websites and apps and used to present content based on your usage habits. If you do not want this, you can always disable it in your device’s browser settings or system settings.

3.2.2 Usage analysis

We use common tracking technologies for the evaluation of device and access data in all our services. Specifically, we use Google Analytics. This allows us to find out how our offer is used by our users in general. Identification cookies and similar identifiers are used. In this way we can find out, for example, which content and topics are particularly popular, at what times our services are used particularly frequently, from which regions (down to the city level) our services are used and which browsers and devices our users generally use. You can disable the processing of your data for usage analysis at any time. If you click on the following link, an opt-out cookie will be set that will prevent future collection of your data when visiting this website: http://tools.google.com/dlpage/gaoptout

4. How does zLabels use my data for advertising?

zLabels uses your data for advertising only as part of adapting the websites to user needs.

5. Who is my data shared with?

zLabels will only pass on your data if this is permitted under German or European data protection law. We work very closely with some service providers, such as technical service providers (e.g. data centre operations). These service providers may only process your data on our behalf under special conditions. Insofar as we use them as a contract processor, the service providers will only be able to access your data to the extent and for the period required for the provision of the respective service.

5.1 Zalando Group’s companies

Within the Zalando Group, many systems and technologies are shared. This allows us to offer you a cheaper, better, safer, more consistent and interesting service. Therefore, within the Zalando Group, only those companies and departments which need access to your data to fulfil our contractual and legal obligations or to fulfil their respective functions within the Zalando Group can access it.

5.2 Technical service providers

We work with technical service providers to provide you with our services. If they process your data outside the European Union, this may result in your data being transferred to a country with a lower standard of data protection than the European Union. In these cases, zLabels ensures that the relevant service providers guarantee a similar level of data protection by contract or otherwise.

5.3 Authorities and other third parties

As far as we are obliged by a decision of the authorities or court or for legal or criminal prosecution, we will pass your data on to law enforcement authorities or other third parties if required.

6. What are my data protection rights?

Under the respective legal requirements, you have the following statutory data protection rights: right to information (Article 15 GDPR), right to deletion (Article 17 GDPR), right to rectification (Article 16 GDPR), right to restriction of processing (Article 18 GDPR), right to data portability (Article 20 GDPR), right of appeal to a Data Protection Authority (Article 77 GDPR), right to withdraw consent (Article 7 (3) GDPR) and the right to object to certain data processing measures (Article 21 GDPR). The contact details for your requests can be found below under “contact person”. Important information: To ensure that your data is not disclosed to third parties during a request for information, please attach sufficient proof of identity to your request by e-mail or by post. The data protection authorities’ responsibilities depend on the location of the responsible body. You can also contact the data protection authority for your place of residence, which will then forward your complaint to the appropriate authority. The lead authority responsible for zLabels is the Berlin Commissioner for Data Protection and Freedom of Information, Friedrichstr. 219, 10969 Berlin, Germany. If you have given consent to the processing of your data, you can withdraw it at any time. A withdrawal does not affect the legitimacy of the processing of your data carried out before your withdrawal. You can object to the processing of your data for advertising purposes, including direct mail, at any time without giving any reason. If we base the processing of your data on a balance of interests in accordance with Article 6 (1) (f) GDPR, you can object to the processing. If you do object, we will ask you to explain why we should not process your information. If your objection is justified, we will examine the situation and will either discontinue or adjust the processing or inform you of our compelling reasons worthy of protection, on the basis of which we may continue the processing.

7. When will my data be deleted?

We will store your personal data for as long as necessary for the purposes set out in this privacy policy, in particular to meet our contractual and legal obligations. We may also store your personal data for other purposes if and as long as the law allows us to store it for specific purposes, including for the defence of legal claims. Deletion may be waived in the cases permitted by law, in the case of anonymous or pseudonymised data, and for deletions which would render the processing for scientific research or statistical purposes impossible or seriously compromised.

8. How does zLabels protect my data?

Your personal data is encrypted so we can transmit it securely. For this we use the SSL (Secure Socket Layer) coding system. Furthermore, we protect our websites and other systems through technical and organisational measures against loss, destruction, access, modification or dissemination of your data by unauthorised persons.

9. Changes to this privacy policy and contact person

As we develop our websites and implement new technologies to improve our service to you, this data protection information may need to be changed. Therefore, we recommend that you review this privacy policy from time to time. Questions about data protection at zLabels can be directed to our data protection officer at any time. The easiest way to reach them is at datenschutz@zalando.de