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Privacy Policy

PRI­VA­CY POL­I­CY
Last updat­ed: May 2018

Pri­va­cy pol­i­cy of Sil­hou­ette Inter­na­tion­al Schmied AG (“Sil­hou­ette”; we”), Ell­bogn­er­straße 24, 4021 Linz, for

- the web­site www​.neubau​-eye​wear​.com (“web­site”)
- the con­tracts with our cus­tomers with regard to the pur­chas­ing of prod­ucts offered via the website. 

Thank you very much for your inter­est in our prod­ucts. In this pri­va­cy pol­i­cy, we pro­vide you with detailed infor­ma­tion about how we process your data and which rights you have with regard to this data pro­cess­ing. Pro­tect­ing your pri­va­cy is a major pri­or­i­ty for us. There­fore, we want to explain your rights and options so that we can fos­ter a long-term busi­ness rela­tion­ship based on trust. We prac­tise data pro­tec­tion in accord-ance with the EU Gen­er­al Data Pro­tec­tion Reg­u­la­tion (GDPR), the Aus­tri­an Tele­me­dia Act (TMG) and oth­er applic­a­ble leg­is­la­tion.
Data pro­tec­tion reg­u­la­tions must always be observed when­ev­er per­son­al data is processed. The scope of this pri­va­cy pol­i­cy is based on the ter­mi­nol­o­gy used in the GDPR. Pro­cess­ing” of per­son­al data essen­tial­ly refers to any han­dling of such data. When­ev­er the data we process can be traced to spe­cif­ic indi­vid­u­als (even if only via third par­ties, with­in an overview or by means of addi­tion­al knowl­edge) and make you iden­ti­fi­able as an indi­vid­ual (par­tic­u­lar­ly when the data dis­clos­es your full name), then this data is essen­tial­ly con­sid­ered to be per­son­al data”.

1. Data pro­cess­ing dur­ing use of the web­site
When­ev­er you vis­it our web­site, we col­lect the fol­low­ing data: IP address.
You can vis­it our web­site with­out hav­ing to dis­close infor­ma­tion about your­self. When­ev­er you access the web­site, only cer­tain access data (your IP address and oth­er meta­da­ta, such as the date and time of access and the request­ing provider) are processed with the sup­port of auto­mat­ed process­es, par-tic­u­lar­ly for the pur­pos­es of secu­ri­ty or improve­ment of the website’s qual­i­ty. This infor­ma­tion does not enable us to iden­ti­fy you per­son­al­ly. The IP anonymiza­tion used on this web­site means that your IP address will be held in trun¬cat¬ed and anonymised form. You can vis­it our web­site for pure­ly infor-mation­al pur­pos­es, to find out about our prod­ucts, ser­vices and activ­i­ties, with­out it becom­ing pos­si-ble for us to link such data to you personally. 

2. Data pro­cess­ing when you become one of our cus­tomers and wish to pur­chase prod­ucts
If you decide to use our ser­vices, you must dis­close cer­tain infor­ma­tion so that our con­tract with you can be exe­cut­ed. For this, you can cre­ate a cus­tomer account. How­ev­er, you can also place an order with­out a cus­tomer account. When you pur­chase a prod­uct, you must pro­vide the fol­low­ing per­son­al data in any case: 

a) First name, sur­name
b) Tele­phone num­ber
c) E-mail address
d) Deliv­ery address, billing address

We require this infor­ma­tion to be able to ful­fil our con­tract with you (art. 6.1.1.b of the GDPR). The data is also saved by us, though we only store the data for as long as we deem rea­son­ably nec­es­sary for the pur­pos­es of ful­fill­ing the con­tract and to the extent per­mis­si­ble by law. In any case, we save your per­son­al data for as long as legal stor­age require­ments apply or peri­ods of lim­i­ta­tion for poten­tial legal claims have not yet expired. If the stor­age of the data is no longer nec­es­sary for the pur­pos­es for which the data was orig­i­nal­ly col­lect­ed (or with­in the scope of a legal­ly per­mis­si­ble change of pur-pose), and there are no fur­ther legal require­ments to con­tin­ue stor­ing it, then we arrange for the data to be deleted.

For the pur­pose of ful­fill­ing our con­tract with you, we must also select an e-com­merce part­ner dur­ing the order­ing process. This part­ner pro­vides us with spe­cif­ic ser­vices in con­nec­tion with the online pur­chase. Such part­ners are con­sid­ered proces­sors” with­in the ter­mi­nol­o­gy of data pro­tec­tion law. For this pur­pose, we will trans­fer your full name and infor­ma­tion about the select­ed prod­uct exclu­sive­ly to the select­ed ser­vice part­ner. If you wish to make use of spe­cif­ic ser­vices with regard to a con­tract you have con­clud­ed with Sil­hou­ette and these ser­vices are han­dled by a ser­vice part­ner, your postal address may be dis­closed to the ser­vice part­ner, if nec­es­sary, or you may vol­un­tar­i­ly share it with them. Such dis­clo­sure of your data is also a nec­es­sary pre­con­di­tion for ful­fill­ing our con­tract with you.
In case you return a prod­uct (par­tic­u­lar­ly when exer­cis­ing your right of with­draw­al), a fur­ther proces­sor will become involved, name­ly: PVS ZMD GmbH, Schleißheimer Straße 93a, 85748 Garch­ing bei München, Ger­many. Should you return prod­ucts that you have pur­chased via our online shop, your full name and postal address will be dis­closed to PVS ZMD GmbH.
Our proces­sors are bound by our data pro­tec­tion prac­tices and always treat your per­son­al data as strict­ly con­fi­den­tial. Unless they have your explic­it con­sent to do so, they will nev­er dis­close your data to third par­ties or use your data for any pur­pos­es oth­er than those nec­es­sary for the ful­fil­ment of their duties towards Sil­hou­ette or based on our explic­it instructions.


3. Pay­ments
If you decide to pur­chase prod­ucts in our online store, either you or, if nec­es­sary, we must con­tract a pay­ment ser­vice provider (also a proces­sor) to car­ry out the trans­ac­tion. In this process, spe­cif­ic (per-son­al) (pay­ment-relat­ed) data is trans­ferred. We have lit­tle influ­ence over the stor­age and pro­cess­ing of this data. The trans­fer of data takes place exclu­sive­ly for the pur­pose of ful­fill­ing our con­tract with you. In some cas­es, the select­ed pay­ment ser­vice provider also col­lects this data them­selves, par­ticu-lar­ly when­ev­er you (must) cre­ate an account with them. In such cas­es, the pri­va­cy pol­i­cy of the provider in ques­tion applies; our pri­va­cy pol­i­cy is only intend­ed to inform you, if nec­es­sary, of which recip­i­ents receive your pay­ment data.
If you select the pay­ment method Sofort bank trans­fer, then, after plac­ing your order, you will be trans­ferred to the web­site of the online provider SOFORT GmbH, There­sien­höhe 12, 80339 Munich, Ger­many. After you have proven your iden­ti­ty, your per­son­al data and per­son­al account data are trans­ferred to SOFORT GmbH, enabling them, for exam­ple, to ver­i­fy your account bal­ance. Please note the addi­tion­al data pro­tec­tion infor­ma­tion from SOFORT GmbH to which you will be referred specif­i­cal­ly when­ev­er you use this ser­vice.
If you select the pay­ment method Cred­it Card, you trans­fer your cred­it card data to us along with your order. We then request for the cred­it card com­pa­ny to ini­ti­ate the pay­ment trans­ac­tion. The pay­ment trans­ac­tion is auto­mat­i­cal­ly car­ried out by the cred­it card com­pa­ny and charged to your card. Dur­ing this process, spe­cif­ic data is trans­ferred to and processed by the cred­it card com­pa­ny. Beyond this indi­vid­ual pay­ment process, we do not trans­fer any per­son­al data to the cred­it card com­pa­ny. For infor­ma­tion about your cred­it card company’s data pro­cess­ing in gen­er­al, please refer to their pri­va­cy pol­i­cy and gen­er­al terms and con­di­tions.
If you select the pay­ment method Pay­Pal, data relat­ed to the pay­ment process is trans­ferred to and processed by Pay­Pal (Europe) S.à r.l. et Cie, S.C.A., 22 – 24 Boule­vard Roy­al, 2449 Lux­em­burg. For more infor­ma­tion, please refer to the pri­va­cy pol­i­cy and gen­er­al terms and con­di­tions of Pay­Pal.

4. Data subject’s rights
One of the main objec­tives of data pro­tec­tion leg­is­la­tion is to grant you cer­tain options for con­trol­ling your per­son­al data after data pro­cess­ing has already begun. For this pur­pose, data sub­jects have var­i­ous rights which we must observe imme­di­ate­ly upon your request (or, in any case, with­in one (1) month of your request). To exer­cise your rights, con­tact us at the fol­low­ing e-mail address: dataprotection@​silhouette-​international.​com. Specif­i­cal­ly, you have the fol­low­ing rights:

a) Should you exer­cise your right to infor­ma­tion, and no legal restric­tions apply, we will pro-vide you with com­pre­hen­sive infor­ma­tion about our pro­cess­ing of your data. To do so, we will pro­vide you with (i) copies of the data (e-mails, data­base excerpts, etc.), as well as in-for­ma­tion relat­ed to (ii) specif­i­cal­ly processed data, (iii) pro­cess­ing pur­pos­es, (iv) cat­e­gories of data being processed, (v) data recip­i­ents, (vi) stor­age lim­its and/​or cri­te­ria for deter­min­ing these, (vii) the ori­gin of the data, and (viii) oth­er infor­ma­tion, as nec­es­sary, depend­ing on your spe­cif­ic case. Please note, how­ev­er, that we can­not issue any doc­u­ments which could infringe upon the rights of oth­er persons.

b) With your right to cor­rec­tion, you can request that we cor­rect infor­ma­tion that we have record­ed incor­rect­ly, that is no longer cor­rect or that is incom­plete (for the spe­cif­ic pro-cess­ing pur­pos­es in ques­tion). Your request will be eval­u­at­ed, dur­ing which time you can request for the data pro­cess­ing in ques­tion to be restrict­ed until the eval­u­a­tion is complete.

c) The right to (data) dele­tion can be exer­cised (i) in the event that there is no neces­si­ty with regard to the pro­cess­ing pur­pose, (ii) in case you with­draw your con­sent, (iii) in case of a spe­cial objec­tion, if the data pro­cess­ing in ques­tion is based on Silhouette’s legit­i­mate in-ter­ests, (iv) in case of improp­er data pro­cess­ing, (v) in the event that there is a legal require-ment to delete the data, and (vi) in case of pro­cess­ing of per­son­al data refer­ring to minors under the age of 16.

d) In spe­cif­ic cas­es, the data sub­ject has a right to restric­tion of pro­cess­ing. After this right is exer­cised, the data in ques­tion can only be stored. In addi­tion to the option of restric­tion dur­ing the eval­u­a­tion peri­od for data cor­rec­tions, this extends to (i) unlaw­ful data pro­cess­ing (inso­far as no dele­tion is request­ed) and (ii) the dura­tion of the eval­u­a­tion of a spe­cial objection.

e) Fur­ther­more, you have a fun­da­men­tal right to object to data pro­cess­ing at any time. This only applies when­ev­er the pro­cess­ing is based on Silhouette’s legit­i­mate inter­ests. Please note, how­ev­er, that legit­i­mate inter­ests can only be invoked as a legal basis for pro­cess­ing activ­i­ties in spe­cif­ic cases.

f) You can also exer­cise your right to com­plain to super­vi­so­ry author­i­ties (see point 11).
Please also note that in some cas­es we will be unable to com­ply with your request due to manda­to­ry, pro­tect­ed rea­sons for pro­cess­ing (weigh­ing of inter­ests) and/​or pro­cess­ing based on the exer­tion, ex-ercise or defence of legal claims (on our side). The same applies in the case of exces­sive requests, in which case (as in the case of com­pli­ance with man­i­fest­ly unfound­ed requests), a fee may be imposed.

5. Data secu­ri­ty
Sil­hou­ette takes all the suit­able tech­ni­cal and organ­i­sa­tion­al mea­sures to ensure that, by default, per-son­al data is only processed to the extent strict­ly nec­es­sary for the busi­ness pur­pose in ques­tion. The mea­sures tak­en by Sil­hou­ette relate to the quan­ti­ty of the col­lect­ed data, the scope of the pro­cess­ing as well as the stor­age lim­its and acces­si­bil­i­ty of the data. Through these mea­sures, Sil­hou­ette ensures that per­son­al data is made avail­able by default only to a strict­ly lim­it­ed and nec­es­sary num­ber of per­sons. No oth­er per­sons are grant­ed access to per­son­al data with­out the explic­it con­sent of the data sub­ject. Fur­ther­more, Sil­hou­ette uses var­i­ous safe­ty mech­a­nisms (back-ups, encryp­tion) to secure its web­site and oth­er sys­tems. These are intend­ed to pro­vide your (per­son­al) data with the great­est pos­si­ble lev­el of pro­tec­tion against loss, theft, destruc­tion, unau­tho­rised access, mod­i­fi­ca­tion or dis­tri­b­u­tion.
All Sil­hou­ette employ­ees are ade­quate­ly informed of all applic­a­ble reg­u­la­tions under data pro­tec­tion law as well as inter­nal data pro­tec­tion rules and data secu­ri­ty pre­cau­tions. They are bound to con­fi­den­tial­i­ty with respect to any infor­ma­tion made known and/​or acces­si­ble to them with­in the scope of their work. The pro­vi­sions of the GDPR are strict­ly observed and per­son­al data is only pro­vid­ed to indi­vid­ual employ­ees to the extent nec­es­sary with regard to the pur­pose of the data col­lec­tion and our oblig­a­tions aris­ing from it. If Sil­hou­ette engages proces­sors, they are bound to us by spe­cif­ic frame­work agree­ments to act in accor­dance with our data pro­tec­tion practice.

6. Links to Third-Par­ty Web­sites
We use links to the third par­ty web­pages on our web­site, which con­sist on the one hand of links to our long-term part­ners, and on the oth­er, of links to social net­works (e.g. Face­book, Twit­ter, Ins­ta-gram, Pin­ter­est). If you click on any of these links, you will be redi­rect­ed direct­ly to the rel­e­vant web­page. The only data that the web­site oper­a­tors will receive is that you have come via our web­site. We there­fore refer you to the pri­va­cy poli­cies of these web­sites. Please note, how­ev­er, that if you do not want a par­tic­u­lar social net­work to assign data col­lect­ed via our web­site to your pro­file in that social net­work, you must log out before click­ing on the link and access­ing it.

7. Cook­ies
We use small pieces of text data called cook­ies” that are stored on your com­put­er when you use our web­site. These help us to opti­mise our ser­vice to make it more user-friend­ly and secure, and to make design improve­ments. In many cas­es, the cook­ies installed will be ses­sion cook­ies”, which will be au-tomat­i­cal­ly delet­ed when you fin­ish your brows­er ses­sion with­out need­ing fur­ther action on your part. Oth­er cook­ies (e.g. those that store your lan­guage pref­er­ences) are stored over a longer peri­od of time, and must be delet­ed man­u­al­ly. Cook­ies con­tain absolute­ly no per­son­al data.
Most browsers auto­mat­i­cal­ly accept cook­ies. How­ev­er, you can change your brows­er set­tings so that cook­ies are either total­ly blocked or only cer­tain types are per­mit­ted (e.g. you can choose to only block third-par­ty cook­ies). Please note that you may not be able to enjoy the full func­tion­al­i­ty of the web­site if you change your cook­ie set­tings. You can find out how to change your set­tings on the most com­mon browsers using the fol­low­ing links: Inter­net Explor­er™: https://​sup​port​.microsoft​.com/…
Safari™: https://​sup​port​.apple​.com/kb/p…
Chrome™: https://​sup​port​.google​.com/chr…
Fire­fox™: https://​sup​port​.mozil​la​.org/en…
Opera™: http://​help​.opera​.com/​L​i​nux/9.…

8. Google Ana­lyt­ics
Our web­site uses Google Ana­lyt­ics, a web­site analy­sis tool by Google Inc., 1600 Amphithe­atre Park-way, Moun­tain View, CA 94043, USA (“Google”). Cook­ies allow Google Ana­lyt­ics to eval­u­ate your usage of a par­tic­u­lar web­site. We will process your data in accor­dance with our legit­i­mate inter­est to col­lect web­site vis­i­tor sta­tis­tics in a cost-effi­cient and con­ve­nient way (Art. 6 Para. 1 Let­ter F of the GDPR reg­u­la­tions).
The infor­ma­tion gath­ered by the cook­ies about your use of the web­site will be trans­mit­ted to Google’s servers in the USA and stored there. We do not store any data that is gen­er­at­ed through Google Ana­lyt­ics. The IP anonymiza­tion used on this web­site means that your IP address will be held in trun­cat­ed form by Google for mem­ber states of the Euro­pean Union as well as oth­er states par­ty to the agree­ment on the Euro­pean Eco­nom­ic Area. In excep­tion­al cas­es, your full IP address will be sent to the USA and short­ened there. Google uses this infor­ma­tion to eval­u­ate your web­site usage for us and to com­pile reports about your web­site activ­i­ty in order to offer us addi­tion­al ser­vices relat­ing to web­site behav­iour and Inter­net usage. Your IP address will not be asso­ci­at­ed with any oth­er data held by Google, and will not there­fore allow your iden­ti­ty to be dis­cerned. Google is a par­tic­i­pant of the EU-US Pri­va­cy Shield, which requires Google to uphold the agree­ment and com­ply with Euro­pean data pro­tec­tion stan­dards. The cer­ti­fi­ca­tion for the Pri­va­cy Shield can be found at https://​www​.pri​va​cyshield​.gov/list.
Using the process described in point 7, you can set up your brows­er pref­er­ences to stop it from stor­ing cook­ies (or restrict third-par­ty cook­ies only) on your com­put­er. More­over, you can pre­vent Google from col­lect­ing and pro­cess­ing data gath­ered from cook­ies track­ing your web­site usage (incl. your IP address) by down­load­ing and installing the appro­pri­ate brows­er plu­g­in (http://​tools​.google​.com/​d​l​p​a​g​e​/​g​a​o​p​t​o​u​t​?​hl=en). Alter­na­tive­ly, you can click here to install an opt-out cook­ie” which will be stored on your device and which also pre­vents Google Ana­lyt­ics from col­lect­ing your data. You will need to repeat this step again if you delete all your cook­ies. How­ev­er, we would also point out that you may not be able to enjoy the website’s full func­tion­al­i­ty if you do so.
You can find more detailed infor­ma­tion about your data pri­va­cy with regard to Google Ana­lyt­ics and how you can man­age it at https://​poli​cies​.google​.com/​p​r​i​v​a​c​y​?​hl=en.

9. Newslet­ter
On our web­site you have the option of sign­ing up to the neubau newslet­ter. To do so, you are required to sub­mit your name and your e-mail address. You can also vol­un­tar­i­ly sub­mit your your coun-try of res­i­dence to receive more per­son­alised infor­ma­tion. We need the data to send you the newslet-ter and address you cor­rect­ly. The neubau newslet­ter will also keep you up-to-date about the lat­est neubau prod­ucts and trends, and will only be sent to those who have vol­un­tar­i­ly pro­vid­ed their e-mail address. Of course, should you wish to stop receiv­ing the newslet­ter at any time, you can click on the unsub­scribe from the newslet­ter” but­ton. Pro­vid­ing there is no fur­ther legal require­ment or legal ba-sis for pro­cess­ing it, the data stored for send­ing the newslet­ter will be delet­ed after you unsub­scribe. We also use the newslet­ter to make sta­tis­ti­cal analy­ses regard­ing your per­son­al data, and we mea­sure the per­for­mance of the newslet­ter by mon­i­tor­ing if the newslet­ter is opened, what con­tent is clicked on and tech­ni­cal infor­ma­tion regard­ing send­ing the newslet­ter. Pro­cess­ing is car­ried out in line with our legit­i­mate inter­est to pro­duce read­ily­ac­ces­si­ble newslet­ter sta­tis­tics that help our mar­ket­ing ef-forts in a cost­ef­fec­tive way.
We use the Eye­pin” newslet­ter ser­vice oper­at­ed by eye­pin GmbH. To utilise the ser­vice, the per­son­al data you vol­un­tar­i­ly pro­vid­ed will be stored on Eyepin’s servers in Aus­tria and Ger­many. Your data will only be used in order to send you the newslet­ter that you ordered.

10. Face­book Pix­el
a) Face­book process­es data in accor­dance with its data pol­i­cy. Here is some gen­er­al infor­ma­tion about how Face­book ads are dis­played accord­ing to its pri­va­cy pol­i­cy: https://​www​.face​book​.com/​p​o​l​i​c​y.php. You can find more spe­cif­ic, detailed infor­ma­tion about Face­book-Pix­el and how it works on Facebook’s Help pages: https://​www​.face​book​.com/​b​u​s​i​n​e​s​s​/​h​e​l​p​/​651294705016616.

b) You can pre­vent Face­book-Pix­el from col­lect­ing and pro­cess­ing your data for the pur­pos­es of dis­play­ing Face­book ads. If you want to con­trol what kind of adverts are dis­played to you on Face­book, you can go to the page Face­book has set up for this pur­pose and fol­low the instruc­tions on con­fig­ur­ing user-tar­get­ed adverts: https://​www​.face​book​.com/​s​e​t​t​i​n​g​s​?​t​a​b=ads. The set­tings cho­sen will be applied across all plat­forms, mean­ing that they will apply to all devices from your desk­top to mobile. 

c) To stop Face­book-Pix­els from col­lect­ing data on our web­site, please click on the fol­low­ing link: Face­book-Opt-Out. Please note: If you click on the link, an opt-out cook­ie will be stored on your device. If you sub­se­quent­ly delete the cook­ies from the brows­er, you will have to click on the link again. More­over, the opt-out only works on the brows­er you used to down­load it and only for the web domain where you clicked on the link.

d) You can fur­ther pre­vent the deploy­ment of cook­ies that mea­sure vis­i­tor num­bers and enable adverts on the deac­ti­va­tion web­page of the Net­work Adver­tis­ing Ini­tia­tive (http://​optout​.net​workad​ver​tis​ing​.org/), and also on the US-based web­site (http://​www​.aboutads​.info/​c​h​oices) or Euro­pean web­site (http://​www​.youron​line​choic​es​.com/​u​k​/​y​o​u​r​-​a​d​-​c​h​o​ices/).

11. Con­tact Form on the Web­site
On our web­site you have the option of fill­ing out a con­tact form to ask us spe­cif­ic ques­tions or get in touch with us. The infor­ma­tion that you sub­mit will only be used to respond to your ques­tion, and will not be stored.

12. Right of Com­plaint
If you decide that we have infringed against incum­bent data pri­va­cy laws, you have the right to file a com­plaint with the rel­e­vant nation­al data pro­tec­tion author­i­ty. The require­ments involved in lodg­ing a com­plaint will depend on the spe­cif­ic nation­al reg­u­la­tions gov­ern­ing the imple­men­ta­tion of GDPR. How­ev­er, we would request that you get in touch with us before­hand so that we can clear up any ques­tions or problems.

13. Con­tact Details for Data Pro­tec­tion Ques­tions, Mes­sages and Requests
Please send ques­tions, noti­fi­ca­tions or requests regard­ing data pro­tec­tion law to the fol­low­ing con­tact address:

Sil­hou­ette Inter­na­tion­al Schmied AG
Ell­bogn­er­straße 24
4021 Linz
Aus­tria

E-mail: dataprotection@​silhouette-​international.​com