Data protection
1. Responsible person
The responsible party within the meaning of the GDPR is:
Kluecino GbR
Kempener Straße 13
50733 Cologne, Germany
Email: info@kluecino.com
Authorized representatives: Philipp Klütsch, Giuliano Saracino
2. Hosting and shop system (Shopify)
Our online shop is operated by Shopify International Ltd. , Victoria Buildings, 2nd Floor, 1-2 Haddington Road, Dublin 4, D04 XN32, Ireland.
Shopify processes personal data on our behalf, e.g.:
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Order data
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IP addresses
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Payment details
Legal basis:
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Article 6 paragraph 1 letter b GDPR (performance of a contract)
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Article 6 paragraph 1 letter f GDPR (legitimate interest in efficient shop operation)
Third-country transfers: Shopify may process data in Canada or the USA. This transfer is based on Standard Contractual Clauses (SCCs) pursuant to Article 46 GDPR.
Note: We have a data processing agreement (DPA) in place with Shopify.
3. Access data / server log files
When you visit our website, the following data is automatically collected:
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IP address
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Date & Time
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Browser type & version
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operating system
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Referrer URL
Purpose: Prevention of misuse, security and stability of the website
Legal basis: Art. 6 para. 1 lit. f GDPR
Storage period: 14 days, then automatic deletion
4. Order processing
We process the following data for order processing:
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Name first Name
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Billing and delivery address
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E-mail address
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Phone number (optional)
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Order details & payment information
Purpose: Contract fulfillment, delivery, payment processing, legal retention obligations
Legal basis: Art. 6 para. 1 lit. b GDPR
Storage duration: up to 10 years
5. Payment service providers
Depending on the chosen payment method, data will be transmitted to:
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Shopify Payments (Stripe Payments Europe Ltd., Ireland) – including credit card, Shop Pay, Apple Pay, and Google Pay. (Stripe acts as the technical payment provider)
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PayPal (Europe) S.à rl, Luxembourg – processing via PayPal Checkout
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Klarna Bank AB, Sweden – e.g. invoice, installment or instant payment
Other payment options (via Shopify Payments or affiliated providers):
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American Express
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Apple Pay
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Bancontact
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EPS
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Google Pay
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ideal
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maestro
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Mastercard
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Shop Pay
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Union Pay
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Visa
Legal basis: Art. 6 para. 1 lit. b GDPR
Note: We have data processing agreements (DPAs) in place between us and the payment service providers.
6. Shipping
For delivery purposes, we transmit the following data to DHL Paket GmbH, Germany :
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name
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Delivery address
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Optionally, email address for shipment tracking.
Legal basis: Art. 6 para. 1 lit. b GDPR
Note: DHL stores the data solely for delivery purposes; it is not shared for marketing purposes.
7. Newsletter
For newsletter subscriptions, we process:
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E-mail address
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(if applicable) Name
Delivery is via: Shopify Email
Legal basis: Art. 6 para. 1 lit. a GDPR (consent)
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The double opt-in procedure is used.
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Proof of consent, including time and IP address, will be stored.
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You can unsubscribe at any time via the unsubscribe link.
8. Postcard mailing / direct marketing
We may use your address data for postal advertising (e.g. new collections, promotions).
Legal basis: Art. 6 para. 1 lit. f GDPR (legitimate interest)
You can object at any time:
Send an email to info@kluecino.com with the following text:
Ladies and Gentlemen
I hereby unsubscribe from receiving your postal advertising at my address [insert your address] with immediate effect.
Please confirm the discontinuation of advertising mailings in writing or by email.
Thank you for your understanding.
Best regards,
[Your name]
9. Cookies and Tracking
9.1 Cookie Consent
We use Shopify's own cookie banner/cookie consent tool . Visitors can reject all cookies or change their settings at any time.
9.2 Technically necessary cookies
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Shopping cart, login, checkout
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Legal basis: Art. 6 para. 1 lit. f GDPR
9.3 Analytics and marketing cookies
We only set these cookies after you have given your consent (opt-in):
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Google Analytics 4 (GA4) – IP anonymization enabled, SCC for data transfer to the USA
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Meta Pixel (Facebook & Instagram) – Interactions for personalized advertising, SCC for data transfer to the USA
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Shopify Audiences – Creating target audiences for marketing
Legal basis: Art. 6 para. 1 lit. a GDPR
Note: Consent can be withdrawn at any time via the banner or the browser.
10. Rights of data subjects
You have the right to:
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Right of access (Art. 15 GDPR)
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Rectification (Art. 16 GDPR)
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Erasure (Art. 17 GDPR)
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Restriction of processing (Art. 18 GDPR)
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Data portability (Art. 20 GDPR)
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Right to object (Art. 21 GDPR)
Right to appeal:
State Commissioner for Data Protection and Freedom of Information NRW
www.ldi.nrw.de
Note: Information and deletion requests will be processed within 1 month.
11. Revocation of consent
Consent can be withdrawn at any time with effect for the future.
Contact: info@kluecino.com
12. SSL/TLS encryption
This website uses SSL/TLS encryption for secure data transmission.
