Privacy Policy

1) INFORMATION ABOUT THE COLLECTION OF PERSONAL DATA AND CONTACT DETAILS OF THE CONTROLLER
1.1 We are pleased that you visit our website and thank you for your interest. Below we inform you about the handling of your personal data when you use our website. Personal data are all data by 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 Claire's Closet. The controller for the processing of personal data is the natural or legal person who, alone or jointly with others, determines 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 padlock symbol in your browser address bar.

2) DATA COLLECTION WHEN VISITING OUR WEBSITE
When you use our website for purely informational purposes — i.e., if you do not register or otherwise provide information to us — we only collect the data that your browser transmits to our server (so-called “server log files”). When you call up our website, we collect the following data that are technically necessary for us to display the website:
- Visited website
- Date and time at the time of access
- Amount of data sent in bytes
- Source/referrer from which you accessed the site
- Browser used
- Operating system used
- IP address used (possibly anonymized)
Processing is carried out pursuant to 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 otherwise. However, we reserve the right to review the server log files retrospectively if there are concrete indications of unlawful use.

3) COOKIES
To make visiting our website attractive and to enable the use of certain functions, we use so-called cookies on various pages. These are small text files stored on your device. Some cookies we use are deleted after the end of the browser session (session cookies). Other cookies remain on your device and allow us or our partners (third-party cookies) to recognize your browser on your next visit (persistent cookies). When cookies are set, they collect and process certain user information such as browser and location data and IP address values to varying degrees. Persistent cookies are automatically deleted after a predetermined period that may vary by cookie.
Some cookies are used to simplify the ordering process by storing settings (e.g., remembering the contents of a virtual shopping cart for a later visit). If individual cookies we implement also process personal data, processing is carried out pursuant to Art. 6(1)(b) GDPR for the performance of a contract or pursuant to Art. 6(1)(f) GDPR to safeguard our legitimate interest in the best possible functionality of the website and a customer-friendly and effective design of the site visit.
We may work with advertising partners who help make our internet offering more interesting for you. For this purpose, cookies from partner companies may also be stored on your hard drive when you visit our website (third-party cookies). If we work with the above advertising partners, you will be informed separately and individually about the use of such cookies and the scope of information collected in the paragraphs below.
Please note that you can set your browser to inform you about the placement of cookies and individually decide whether to accept them, or to exclude acceptance of cookies for certain cases or in general. Each browser is different in how it manages cookie settings. This is described in each browser’s help menu, which explains how you can change your cookie settings. You can find this for the respective browsers at the following links:
Internet Explorer: https://support.microsoft.com/de-de/help/17442/windows-internet-explorer-delete-manag e-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/kb/ph21411?locale=de_DE
Opera: https://help.opera.com/en/latest/web-preferences/#cookies
Please note that if you do not accept cookies, the functionality of our website may be limited.

4) CONTACT
When you contact us (e.g., via contact form or e‑mail), personal data are collected. Which data are collected in the case of a contact form is apparent from the respective form. These data are stored and used exclusively for the purpose of responding to your concern and for the associated technical administration. The legal basis for processing the data is our legitimate interest in answering your request pursuant to Art. 6(1)(f) GDPR. If your contact aims at concluding a contract, the additional legal basis for processing is Art. 6(1)(b) GDPR. Your data will be deleted after final processing of your inquiry, which is the case when the circumstances indicate that the matter has been conclusively resolved and provided that no statutory retention obligations oppose deletion. For contact or to exercise your rights, please use: support@clairesclosetnz.com

5) DATA PROCESSING WHEN OPENING A CUSTOMER ACCOUNT AND FOR CONTRACT EXECUTION
Pursuant to Art. 6(1)(b) GDPR, personal data are further collected and processed if you provide them to us for the performance of a contract or when opening a customer account. Which data are collected is apparent from the respective input forms. Deletion of your customer account is possible at any time and can be requested by message to support@clairesclosetnz.com. We store and use the data you provide for contract processing. After complete fulfillment of the contract or deletion of your customer account, your data will be blocked in view of tax and commercial retention periods and deleted after these periods expire, provided you have not expressly consented to further use of your data or we have reserved a legally permitted further use of the data, about which we will inform you below.

6) USE OF YOUR DATA FOR DIRECT MARKETING
6.1 Registration for our e‑mail newsletter
If you sign up for our e‑mail newsletter, we will regularly send you information about our offers. The only required information for sending the newsletter is your e‑mail address. Any additional data provided is voluntary and used to address you personally. For sending the newsletter we use the double opt‑in procedure. This means we will only send you a newsletter after you have explicitly confirmed that you consent to receiving newsletters. We then send a confirmation e‑mail asking you to confirm by clicking a link that you want to receive newsletters in the future.
By activating the confirmation link you give your consent to the use of your personal data pursuant to Art. 6(1)(a) GDPR. When you register for the newsletter, we store your ISP‑assigned IP address and the date and time of registration to trace possible misuse of your e‑mail address at a later date. The data collected during newsletter registration are used solely for the purpose of promotional contact via newsletter. You can unsubscribe from the newsletter at any time using the link provided in the newsletter or by notifying us at support@clairesclosetnz.com. After unsubscribing, your e‑mail address will be promptly removed from our newsletter distribution list unless you have expressly consented to further use of your data or we reserve a further legally permitted use of the data and inform you accordingly in this policy.
6.2 Sending the e‑mail newsletter to existing customers
If you provided your e‑mail address to us when purchasing goods or services, we reserve the right to regularly send you offers for similar goods or services from our range by e‑mail. For this we do not need a separate consent from you. Processing is based solely on our legitimate interest in personalized direct marketing pursuant to Art. 6(1)(f) GDPR. If you initially objected to the use of your e‑mail address for this purpose, we do not send e‑mails. You have the right to object to the use of your e‑mail address for the aforementioned advertising purpose at any time for the future by notifying us at support@clairesclosetnz.com. Only transmission costs according to basic tariffs will apply. After receipt of your objection, the use of your e‑mail address for advertising purposes will be discontinued immediately.

7) DATA PROCESSING FOR ORDER HANDLING
7.1 The personal data we collect are passed on to the shipping company commissioned with delivery, insofar as this is necessary for delivery of the goods. We pass on your payment data to the commissioned bank insofar as this is required for payment processing. If payment service providers are used, we explicitly inform you below. The legal basis for passing on the data is Art. 6(1)(b) GDPR.
7.2 Use of payment service providers
- PayPal
If you pay via PayPal, credit card via PayPal, direct debit via PayPal or — if offered — “purchase on account” or “instalment payment” via PayPal, we pass on your payment data for payment processing to PayPal (Europe) S.a.r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg. The transfer is made pursuant to Art. 6(1)(b) GDPR and only insofar as necessary for payment processing.
For certain payment methods via PayPal, PayPal reserves the right to perform a credit check. For this purpose, PayPal may pass your payment data to credit agencies pursuant to Art. 6(1)(f) GDPR on the basis of PayPal’s legitimate interest in assessing your creditworthiness. The result of the credit check regarding the statistical probability of payment default is used by PayPal to decide on providing the respective payment method. The credit check may include score values based on mathematically-statistical procedures. Address data are among the factors considered. For more privacy information, see PayPal’s privacy policy: https://www.paypal.com/de/webapps/mpp/ua/privacy-full
You can object to this processing at any time by contacting PayPal. However, PayPal may still be entitled to process your personal data insofar as this is necessary for contractually required payment processing.
- SOFORT
If you choose the payment method “SOFORT,” payment processing is handled by SOFORT GmbH, Theresienhöhe 12, 80339 Munich, Germany (“SOFORT”), to which we pass on the information you provided during the ordering process along with information about your order pursuant to Art. 6(1)(b) GDPR. SOFORT is part of the Klarna Group (Klarna Bank AB (publ), Sveavägen 46, 11134 Stockholm, Sweden). Your data are passed on exclusively for the purpose of payment processing with SOFORT and only insofar as necessary. Further information about SOFORT’s privacy policy is available at: https://www.klarna.com/sofort/datenschutz

8) CONTACT FOR REVIEW REMINDER
Own review reminder (not sent by a customer review system)
We use your e‑mail address for a one‑time reminder to submit a review of your order for the review system we use, provided you gave your explicit consent in accordance with Art. 6(1)(a) GDPR during or after your order.
You may revoke your consent at any time by sending a message to support@clairesclosetnz.com.

9) USE OF SOCIAL MEDIA: SOCIAL PLUGINS
9.1 Facebook plugins with Shariff solution
Special additional customs clearance costs and/or import duties are not included in the price and are borne by the customer.
Our website uses so-called social plugins (“plugins”) of the social network Facebook, operated by Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA (“Facebook”).
To increase the protection of your data when visiting our website, these buttons are not integrated as plugins directly but only as an HTML link. This ensures that when a page containing such buttons is called up, no connection to Facebook’s servers is made. If you click the button, a new browser window opens and calls up Facebook’s page where you can interact with the plugins (possibly after entering your login data).
Facebook Inc. in the USA is certified under the U.S.–EU Privacy Shield, which ensures compliance with the level of data protection applicable in the EU.
Purpose and scope of data collection and further processing and use of the data by Facebook, as well as your rights and configuration options to protect your privacy, can be found in Facebook’s data policy: https://www.facebook.com/policy.php
9.2 Google+ plugins as Shariff solution
Our website uses social plugins of the social network Google+ operated by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”).
To increase data protection, these buttons are embedded only as an HTML link so that no connection to Google+ servers is made when a page is accessed. If you click the button, a new browser window opens and calls up the Google+ page where you can interact with the plugins (possibly after entering your login data).
Google LLC in the USA is certified under the U.S.–EU Privacy Shield. Purpose and scope of data collection and further processing and use of the data by Google and your rights and privacy settings are available at: https://www.google.com/intl/de/policies/privacy/
9.3 Instagram plugin as Shariff solution
Our website uses social plugins of the online service Instagram operated by Instagram LLC, 1601 Willow Rd, Menlo Park, CA 94025, USA (“Instagram”).
To increase data protection, these buttons are embedded only as an HTML link so that no connection to Instagram servers is made when a page is accessed. If you click the button, a new browser window opens and calls up the Instagram page where you can interact with the plugins (possibly after entering your login data).
Instagram LLC in the USA is certified under the U.S.–EU Privacy Shield. Purpose and scope of data collection and further processing and use of the data by Instagram and your rights and privacy settings are available at: https://help.instagram.com/155833707900388/

10) ONLINE MARKETING
10.1 DoubleClick by Google
This website uses the online marketing tool DoubleClick by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“DoubleClick”).
DoubleClick uses cookies to show users relevant ads, improve reports on campaign performance, or prevent a user from seeing the same ads multiple times. Google captures via a cookie ID which ads are shown in which browser and can thus prevent multiple displays. Processing is based on our legitimate interest in optimal marketing of our website pursuant to Art. 6(1)(f) GDPR.
DoubleClick can also record conversions related to ad requests using cookie IDs (e.g., when a user sees a DoubleClick ad and later visits the advertiser’s website with the same browser and makes a purchase). According to Google, DoubleClick cookies do not contain personally identifiable information.
By using these marketing tools, your browser automatically establishes a direct connection with Google’s server. We have no influence over the scope and further use of the data collected by Google and therefore inform you according to our knowledge: By including DoubleClick, Google receives the information that you have called up the corresponding part of our website or clicked an ad. If you are registered with a Google service, Google may assign the visit to your account. Even if you are not registered or not logged in, the provider may obtain and store your IP address.
If you wish to opt out of this tracking, you can block cookies for conversion tracking by configuring your browser to block cookies from the domain www.googleadservices.com, or visit https://www.google.de/settings/ads (note: this setting is deleted when you clear cookies). Alternatively, you can learn about and manage cookie settings at the Digital Advertising Alliance: www.aboutads.info. You can also configure your browser to be informed about cookie placement and decide individually whether to accept them or reject them. Disabling cookies may limit website functionality.
Google LLC in the USA is certified under the U.S.–EU Privacy Shield. Further information on DoubleClick privacy: https://www.google.de/policies/privacy/
10.2 Use of Google AdWords Conversion Tracking
This website uses Google AdWords and AdWords conversion tracking by Google LLC. We use Google AdWords to draw attention to our offers on external websites with advertisements. We can determine how successful the individual advertising measures are relative to campaign data. Our aim is to show you ads that are of interest to you, make our website more interesting and achieve fair advertising cost accounting.
The conversion tracking cookie is set when a user clicks an AdWords ad. Cookies are small text files stored on your system and usually expire after 30 days. They are not used for personal identification. If the user visits certain pages and the cookie has not yet expired, Google and we can recognize that the user clicked the ad and was redirected to that page. Each AdWords customer receives a different cookie so cookies cannot be tracked across AdWords customers’ websites. Information obtained with the conversion cookie is used to create conversion statistics for AdWords customers who have opted into conversion tracking. Customers receive the total number of users who clicked their ad and were redirected to a page with a conversion tracking tag, but no information that personally identifies users. If you do not want to participate in tracking, you can disable the Google conversion tracking cookie in your browser settings; you will then not be included in conversion tracking statistics. We use Google AdWords based on our legitimate interest in targeted advertising pursuant to Art. 6(1)(f) GDPR.
Google LLC in the USA is certified under the U.S.–EU Privacy Shield. Further information on Google’s privacy: https://www.google.de/policies/privacy/
You can permanently disable ad customization cookies by preventing them through your browser settings or by downloading and installing the browser plug‑in available at: https://www.google.com/settings/ads/plugin?hl=de
Please note that some functions of this website may be limited if you deactivate cookies.

11) WEB ANALYTICS SERVICES
Google (Universal) Analytics
- Google Universal Analytics
This website uses Google Analytics, a web analytics service by Google LLC. Google Analytics uses cookies which are stored on your computer and enable analysis of your use of the website. The information generated by the cookie about your use of this website (including the shortened IP address) is usually transferred to and stored on a Google server in the USA.
This website uses Google Analytics only with the "_anonymizeIp()" extension which ensures anonymization of the IP address by truncation and prevents direct personal reference. The IP address is truncated within EU member states or in other states party to the EEA agreement before transmission to the USA. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and truncated there. In such exceptional cases processing is based on Art. 6(1)(f) GDPR on the basis of our legitimate interest in statistical analysis of user behavior for optimization and marketing purposes.
On our behalf, Google will use this information to evaluate your use of the website, compile reports on website activity and provide other services related to website and internet usage to us. The IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data by us.
You can prevent the storage of cookies by adjusting your browser software; however, you may then not be able to use all functions of this website fully. You can also prevent Google from collecting the data generated by the cookie about your use of the website (including your IP address) and processing these data by Google by downloading and installing the browser plug‑in available at: https://tools.google.com/dlpage/gaoptout?hl=de
Alternatively, or for mobile browsers, click the following link to set an opt‑out cookie that prevents future collection by Google Analytics on this website (this opt‑out cookie works only in this browser and only for this domain; if you clear your cookies, you must click the link again): Google Analytics deactivate
Google LLC in the USA is certified under the U.S.–EU Privacy Shield.
This website also uses Google Analytics for cross-device analysis of visitor flows performed via a user ID. On first visit a user is assigned a unique, persistent and anonymized ID used across devices, enabling interaction data from different devices and sessions to be assigned to a single user. The user ID contains no personal data and does not transmit such to Google.
You can object to the collection and storage of data via the user ID with future effect. For this you must disable Google Analytics on all systems you use, e.g., in another browser or mobile device. Deactivation can be done using Google’s browser plug‑in (https://tools.google.com/dlpage/gaoptout?hl=de). Alternatively, or for mobile browsers, click the link above to set an opt‑out cookie that prevents future collection by Google Analytics on this website.
Further information on Universal Analytics: https://support.google.com/analytics/answer/2838718?hl=de&ref_topic=6010376

12) RETARGETING / REMARKETING / RECOMMENDATION ADVERTISING
Facebook Custom Audience via the pixel method
This website uses the “Facebook Pixel” of Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA (“Facebook”). If you give explicit consent, this allows tracking of user behavior after they have seen or clicked a Facebook ad. This procedure serves to evaluate the effectiveness of Facebook ads for statistical and market research purposes and can help optimize future advertising measures.
The collected data are anonymous to us and do not reveal user identities. However, data are stored and processed by Facebook, so linking to the user profile is possible and Facebook can use the data for its own advertising purposes according to Facebook’s Data Use Policy (https://www.facebook.com/about/privacy/). Facebook and its partners may be enabled to display ads on and off Facebook. A cookie may be stored on your device for these purposes. These processing operations take place only with your explicit consent under Art. 6(1)(a) GDPR.
Consent for use of the Facebook Pixel may only be given by users aged over 13. If you are younger, please ask your guardians for permission.
Facebook Inc. in the USA is certified under the U.S.–EU Privacy Shield.
To disable use of cookies on your computer, configure your browser so that no cookies can be stored or so that existing cookies are deleted. Disabling all cookies may result in loss of certain functions on our site. You can also opt out of third‑party cookies such as Facebook via the Digital Advertising Alliance at: https://www.aboutads.info/choices/
Google AdWords Remarketing
Our website uses Google AdWords Remarketing to advertise this website in Google search results and on third‑party websites. Provider is Google LLC. For this purpose, Google sets a cookie in your browser that, via a pseudonymous cookie ID and based on visited pages, enables interest‑based advertising. Processing is based on our legitimate interest

RIGHTS OF THE DATA SUBJECT 13.1 Applicable data protection law grants you comprehensive rights (access and intervention rights) vis‑à‑vis the controller regarding the processing of your personal data. These include in particular:

Right of access (Art. 15 GDPR): right to information about the personal data we process about you, processing purposes, categories of data, recipients or categories of recipients, planned storage period or criteria for determining it, existence of rights to rectification, erasure, restriction of processing, objection, complaint to a supervisory authority, origin of the data if not collected from you, existence of automated decision‑making including profiling and meaningful information about the logic involved and the envisaged effects, and guarantees pursuant to Art. 46 GDPR when transferring data to third countries.
Right to rectification (Art. 16 GDPR): right to immediate correction of inaccurate data and completion of incomplete data.
Right to erasure (Art. 17 GDPR): right to request deletion of your personal data if statutory conditions are met (subject to exceptions such as legal retention obligations or necessity for assertion/defence of legal claims).
Right to restriction of processing (Art. 18 GDPR): right to request restriction of processing in certain cases (e.g., while accuracy is contested, instead of erasure when processing is unlawful but you request restriction, when data are needed for legal claims, or when you have objected and a balancing of interests is pending).
Right to notification (Art. 19 GDPR): if you have asserted rectification, erasure or restriction, we must inform recipients of disclosed data of these measures, unless impossible or involving disproportionate effort; you have the right to be informed about those recipients.
Right to data portability (Art. 20 GDPR): right to receive personal data you provided in a structured, commonly used and machine‑readable format or to request transmission to another controller, where technically feasible.
Right to withdraw consent (Art. 7(3) GDPR): you may withdraw any consent at any time with future effect; withdrawal does not affect lawfulness of processing performed up to withdrawal.
Right to lodge a complaint (Art. 77 GDPR): you may complain to a supervisory authority if you believe processing violates the GDPR (for example in the Member State of your habitual residence, workplace or the place of the alleged infringement).

13.2 Right to object If we process your personal data based on a balancing of interests (legitimate interests), you have the right to object at any time for reasons arising from your particular situation to the processing with future effect. If you object, we will cease processing the affected data unless we can demonstrate compelling legitimate grounds that override your interests, rights and freedoms, or processing serves the establishment, exercise or defence of legal claims. If your personal data are processed for direct marketing, you have the right to object at any time to processing of personal data concerning you for such marketing purposes; upon objection we will cease processing for direct marketing purposes. To exercise any of the rights above or to object, please contact the controller at support@clairesclosetnz.com.

14. DURATION OF STORAGE OF PERSONAL DATA The storage duration for personal data is determined by the respective statutory retention periods (e.g., commercial and tax law retention obligations). After expiry of those periods, the relevant data are routinely deleted unless they are still required for contract performance or initiation, or unless we have a continuing legitimate interest in further storage.