Privacy Policy

1. Introduction

We - Kramer Equestrian Ltd. - and hereinafter called "Kramer Equestrian", "we", "us" or "our" - take a personal interest in you being comfortable with our online shop as a visitor and as a customer. This includes proper handling of your personal data - hereinafter called "data" - by adhering to the provisions of the General Data Protection Regulation, hereinafter called the GDPR. In this declaration we explain which data we collect and for which purpose/s we use same. This document also contains further information on your rights and how you can access, amend or erase your personal data.

2. Responsible Company

The company responsible for collecting, processing and utilising your personal data within the meaning of the GDPR and other data protection regulations is:

Kramer Equestrian Ltd.
Woodview Road
Paignton
Devon
TQ4 7SR
Great Britain

Managing Director:
Frank Schmeckenbecher
Company registration no.: 9744740
Company tax reference no.: 333 32544 23250
VAT registration no.: GB 228 2887 78

E-mail info@kramer.co.uk,
Phone 01803 - 420125*
Website: www.kramer.co.uk

*Calls from landlines are typically charged up to 13p per minute. Call costs from mobiles vary according to the calling plan chosen.

3. Company Data Protection Officer

You can contact the data protection officer named below commissioned by Kramer Equestrian under the provisions of section 4 articles 37 - 39 GDPR by post or e-mail regarding information, comments and complaints concerning data protection matters provided, you can clearly identify yourself to:

Woodview Road
Paignton
Devon
TY4 7SR
Great Britain

E-mail: privacy@kramer.co.uk

4. Collection, Processing and Utilisation of Personal Data
4.1. What is Personal Data?

Personal data is understood to include all details permitting direct identification of a person. This includes name, address, date of birth, payment information, contact details such as telephone number or e-mail address and the IP address that identifies the device you use to visit the Kramer Equestrian online shop.

4.2. Which Personal Data is Collected?

You can access all our online shop pages without actually having to give any personal details.
Your computer or mobile device automatically sends data to us when it accesses our website. This data is needed so that we can make our online shop available to you. See 4.3.2 below for more information on the scope, processing and utilisation of this data.
Personal data is only recorded by us if you advise us voluntarily thereof, e.g. by opening a customer account, submitting an order, registering for our newsletter, ordering a catalogue or contacting our customer service (using the contact and/or address change form or by e-mail).

4.3. How do we utilise Personal Data?
4.3.1. Legal Basis for processing Personal Data

If we obtain permission from you to process your personal data, article 6 paragraph 1 lit. a GDPR is the legal basis for processing personal data.
For processing personal data needed to perform a contract, to which you are a party, article 6 paragraph 1 lit. b GDPR is the legal basis there for. This also applies to processing transactions needed to perform pre-contractual measures.
If processing of personal data is necessary to fulfil a legal obligation on the part of Kramer Equestrian then article 6 paragraph 1 lit. c GDPR provides the legal basis for same.
If such processing is necessary to safeguard the justified interests of Kramer Equestrian or a third party, except where such interest is overridden by your interests or fundamental rights and liberties, which require protection of personal data, then article 6 paragraph 1 lit. f GDPR provides the legal basis for same.
Which personal data we use for which specific purpose/s is detailed below.

4.3.2 Accessing a Website

Your computer or mobile device sends data when it accesses our website. This includes the operating system of your computer or device, the browser type you use to visit our online shop, which link, if any you used to access our site, the date and time of access, the duration thereof, the access status and the country from which you access our site. These data sets do not consist of personal data. On access, the IP address is communicated but this does not permit identification of any person as it is not stored together with any other personal data. The aforementioned data is only available to us in form of statistics, which ensures no individual person can be identified.
Said data is only saved to enable us to make our website available. Said data also serves to optimise the website and technically administer our online shop.
These purposes constitute our interest in data processing per article 6 paragraph 1 lit. f GDPR.
Technical logs containing an IP address are kept for a maximum of six months for evaluation and detection purposes and support of investigative authorities concerning criminal activities. Events of significance to data protection are kept in central data protection log files for a maximum duration of one year.
As collection and processing of the aforementioned data ensures website availability, such processing cannot be objected to.

4.3.3 Customer Account Registration

At Kramer Equestrian you have the option of creating a personal, password-protected customer account after stating your personal data. We hope to make your Kramer Equestrian shopping experience easier with this account. You also have the option of accessing your order history and personal data at any time and to amend same yourself without the aid of our customer service.

The following personal data is recorded when registering:

  • form of address
  • first and last names
  • address
  • country
  • e-mail address
  • Other data such as title, borough / county or telephone number may optionally be entered.

When registering you agree to Kramer Equestrian utilising your personal data to make the following services available to you:

  • independent administration of your customer data (payment methods, shipping addresses, access data)
  • simple order procedure using pre-filled forms
  • creation and processing of watch lists
  • saving and processing shopping baskets
  • creating and processing a wish list that can be e-mailed to friends

Registration and the associated entering of your personal data is voluntary if you do not intend to make a contract of sale with Kramer Equestrian.
The legal basis for processing the data, subject to your agreement being in hand, is article 6 paragraph 1 lit. a GDPR.
Please keep your access data secret to prevent misuse. Kramer Equestrian cannot accept any liability whatsoever for any unauthorised third party utilising your customer account.
The customer account remains in existence for as long as you, as a customer, wish.
You always have the option of cancelling your registration and having your personal data erased if no longer needed by us, to meet legal or contractual obligations (e.g. contract performance, handling complaints under guarantee) and the law does not dictate otherwise.
Please get in touch with our data protection officer
via e-mail at privacy@kramer.co.uk

or

by post
Kramer Equestrian Ltd.
Woodview Road
Paignton
Devon
TQ4 7SR
Great Britain

Please mark for the attention of the data protection officer and include clear identification of your person to have your customer account closed.

4.3.4. Ordering from Kramer Equestrian

By ordering anything from our online shop you enter into a contract of sale with Kramer Equestrian. We need the following information, which you can enter in the shopping basket forms, to perform any such contract:

  • form of address
  • first and last names
  • address
  • country
  • e-mail address
  • and shipping address if different from that given above
  • we also need credit/debit/debit card data and other payment information for some payment methods

Entering your data when ordering from our online shop serves the purposes given below:

  • Name, billing address and shipping address
    We need this information to process your order. Your address data is sent to UPS to ensure delivery of your order. Further information on our parcel service and shipping and forwarding agent is given under 5.6 below.
  • E-mail address
    Your e-mail address is used by us to send you a confirmation of order and shipment. We reserve the right to contact you by e-mail if we have any queries. Automatic confirmation will be sent to you if you return goods using this data. You can be sure we will only use your e-mail address to contact you on your order or our newsletter.
  • Payment information (e.g. credit/debit card data)
    Your credit/debit card data is requested when handling your order payment by credit/debit card (card type, owner, number, validity). This is passed on to our payment services company who then debit your card. Further information on our payment services company is given in 5.3 below.

When ordering, you agree to us using your personal data to process the order and save same, so we can meet our legal and contractual duties (e.g. handling complaints under guarantee) and statutory retention obligations.
Article 6 paragraph 1 lit. b GDPR is the legal basis for processing your personal data to perform a contract.
Said data will automatically be erased after ten years unless legal requirements dictate otherwise. Premature blocking and anonymisation of your data is feasible if the data is no longer needed to meet contractual or legal duties.
Please contact our data protection officer

via e-mail at privacy@kramer.co.uk

or

by post
Kramer Equestrian Ltd.
Woodview Road
Paignton
Devon
TQ4 7SR
Great Britain

Please mark for the attention of the data protection officer and include clear identification of your person if you want us to erase your personal data.

4.3.5 Customer Service Enquiries

Our customer service can be contacted if you have any queries, requirements or suggestions.

They can be reached by:

  • phone at 01803 - 420125* (calls from landlines are typically charged up to 13p per minute, call costs from mobiles vary according to the calling plan chosen)
  • e-mail at info@kramer.co.uk
  • using the contact form in our online shop
  • using the change of address form in our online shop
  • post

To enable our customer service staff to properly handle your request and verify your identity, using the contact data included, in the information supplied, when opening your customer account, if your request is connected to that account, personal data is collected and stored when you get in touch with them.

Our online shop contact form asks for the following data:

  • customer number
  • form of address
  • first and last names
  • address
  • country
  • contact data (e-mail, optionally telephone number)
  • content of your request

If you use the online shop contact form you will be asked to agree to your personal data being processed.
Your personal data will only be used to handle your request and to verify your identity if your request is connected to your customer account (data reconciliation). If you use any other form of communication with us, the data you provide will be saved. Please note that we may ask for further details if same are needed to handle your request or to verify your identity in order to do so. No data is passed on to any third party except in the case of orders. In this latter case, your personal data will be sent on to our service provider to meet your order as laid down in 4.3.4 and 4.3.6 herein.
The legal basis for data processing is article 6 paragraph 1 lit. a GDPR, subject to signified agreement in our contact form.
Data processing, if you contacted us by any other means, is per article 6 paragraph 1 lit. f GDPR. If your enquiry is intended to serve the entering of any contract of sale with us, the processing of personal data is also in compliance with article 6 paragraph 1 lit. b GDPR.
Personal data collected by customer service and other information acquired in the course of customer contacts must by law be retained for ten years and then automatically be erased.
All personal data collected by us as a result of you contacting us will be erased on request unless the law dictates otherwise.

Please contact our data protection officer if you object to your personal data being utilised and/or processed by us

via e-mail at privacy@kramer.co.uk

or

by post
Kramer Equestrian Ltd.
Woodview Road
Paignton
Devon
TQ4 7SR
Great Britain

Please mark for the attention of the data protection officer and include clear identification of your person.

4.3.6. Advertising Purposes

We always use two communication channels to advertise:

  • we send newsletters by e-mail, and
  • mailings by post (catalogues, postcards)
4.3.6.1 Sending Newsletters

You ticked the "Newsletter" box in our online shop to receive our free newsletter.

You were asked to enter the following personal information in the form provided:

  • e-mail address

optional:

  • form of address
  • first and last names

The e-mail address is needed to ensure the newsletter is sent to the desired address. Form of address and full name are requested so that we can personalise our newsletter. If you are a registered customer with us, we can process data in your shopping basket to personalise your newsletter, in cooperation with our web analysis service Econda. More information on our personalised newsletters is given at 7.1 below.
The legal basis for processing data after registration as a newsletter subscriber is article 6 paragraph 1 lit. a GDPR if you have signified agreement to us doing so.
The legal basis for us sending you a dynamic newsletter that includes products in your shopping basket and the associated processing of your personal data, is article 6 paragraph 1 lit. f GDPR, provided that your interests or fundamental rights and liberties are not overriding, taking into consideration your reasonable expectations based on your relationship with us and overriding legitimate interest per recital 47 GDPR.
We use an opt in procedure in confirming your newsletter subscription, i.e. we first send you our newsletter after you have ticked the relevant checkbox in the form provided, agreeing to same and the associated recording, use and processing of your personal data. In our newsletter form, the procedure is to use the double opt in procedure, i.e. you receive notification by e-mail from us asking you to confirm your subscription by clicking the link contained therein.
The personal data we collect when you subscribe to our newsletter is saved for the duration of said subscription. Your data ceases to be used or processed to send you a newsletter when that subscription expires and/or you cancel same. We then erase your data from our newsletter protocols, unless the law dictates otherwise.
If you wish to cancel your newsletter subscription you can do so in several ways, as elucidated below.
Information on recording, using and processing personal data via the advertising media we use is found hereinafter.

  • "Newsletter" menu choice
    Click on the "newsletter" menu choice in our online shop and enter the e-mail address in the appropriate field to which we sent your newsletter. Choose the "Cancel newsletter" option and send the form off. You will then be sent an e-mail with a confirmation link. Click that link to have your address erased from the newsletter distribution list.
  • Customer service
    We would be happy to handle the matter personally. If you wish to cancel your newsletter subscription you can contact our customer service at any time via any means in 4.3.5 herein to do so.
  • Cancelling your newsletter subscription in the newsletter
    Each newsletter has a cancellation link footer that you can use to cancel your subscription whenever you wish. Just click on the link and your subscription will be cancelled.
4.3.6.2 Postal Advertising

We inform existent customers regularly about interesting campaigns, events and new products and/or services in the form of postal advertising.

The following personal data is recorded, processed and used in doing so:

  • first and last names
  • address

Advertising mass mailing is used to inform existent customers of new products and/or services and pending events of potential interest those which might offer said customers financial savings in the form of rebate campaigns.
The legal basis for processing your personal data for postal advertising purposes is article 6 paragraph 1 lit. f GDPR, provided that your interests or fundamental rights and liberties are not overriding, taking into consideration your reasonable expectations based on your relationship with us and not overriding legitimate interest per recital 47 GDPR.
Sending out postal advertising, and hence the processing and use of your personal data in this connection, ceases immediately as you object thereto. The data will be saved as the law dictates. On expiry of any retention period laid down in law your data will be erased automatically.

If you no longer want to receive advertising from us by mail then please contact our data protection officer

by e-mail at privacy@kramer.co.uk

or

by post
Kramer Equestrian Ltd.
Woodview Road
Paignton
Devon
TQ4 7SR
Great Britain

marked for the attention of the data protection officer and include clear identification of your person if you want us to erase your personal data.

4.3.7 Prize Draws

If you participate in any prize draw held by us then we would request you to please provide us with the necessary personal data to do so. Depending on the competition that data may include

  • first and last names
  • address
  • contact information (e-mail address and/or telephone number)

Please refer to the relevant rules of the individual competition concerned to ascertain the applicable data protection regulations.

4.3.8. Employment Applications

Interested in a vacant position with us that we are advertising and that you would like to apply for? We prefer applications for employment sent by e-mail or post to the recipient address/es given in the aforementioned advertisement.
The personal data you provide in said application will be treated and processed in compliance with the GDPR.

The personal data you send us in any such application depends on you but usually includes

  • information about your person (first and last names, date of birth, address)
  • contact data (telephone number, mobile phone number, e-mail address, postal address)
  • education and training data (school and professional qualifications, degrees with evidence thereof)
  • information on your career to date (past and present employers and employment references)
  • other qualifications
  • photo for your job application
  • salary expectations
  • letter of application for employment

Processing, use and saving of the data you send us with your application for employment is undertaken for the sole purpose of meeting the recruitment requirements for the position advertised. No such data is passed on to any third party. Your data is only seen by persons involved in the recruiting procedure. All our staff are obligated to keep all data you send us confidential.
The legal basis for processing, using and saving the employment application information you send us is article 6 paragraph 1 lit. f GDPR and § 26 Federal Data Protection Act (FDPA) (new).
Said personal data will be erased three months after completion of the recruitment procedure. If your application is successful and results in an employment relationship with us then we will keep the documents you sent us with your application for employment for the duration of that employment relationship.

You always have the right to request information on the data we keep that concerns you. We are always happy to advise you on the use, storage and processing and purpose of processing. You may object to your data being used for the purpose/s aforementioned.
To do so please contact our data protection officer
by e-mail at privacy@kramer.co.uk

or

by post
Kramer Equestrian Ltd.
Woodview Road
Paignton
Devon
TQ4 7SR
Great Britain

Please mark for the attention of the data protection officer.

5. Passing Personal Data on to Service Providers

We do not send personal data on to unauthorised third parties. However, it can sometimes be necessary to pass said data on to our commissioned service provider to perform a contract of sale or meet other needs on your part such as sending you postal advertising. We warrant that we only pass on such data that is properly and appropriately designated and that service providers commissioned by us will only use same to handle the specific task/s we have entrusted them with. Data is passed on in the cases detailed below.

5.1. Software used in handling Orders and Shipment and making our Online Shop available

We use the D&G Versandhaus System VS/4 from

D&G Software GmbH
Im Ermlisgrund 6
76337 Waldbronn-Reichenbach
Germany
- hereinafter called D&G -

We process and save data sent to our customer services via our online shop or other communications means with this software. This includes the data categories:

  • personal master data (name, surname, address)
  • customer account and sales data
  • payment information
  • contact history (telephone, e-mail)
  • contract master data
  • customer history (e.g. date of last purchase, total sales, total balance)

Our online shop is operated and made available by the D&G subcontractor

Websale AG
Gutenstetter Str. 2
90449 Nuremberg
Germany

Kramer Equestrian, D&G and the subcontractor Websale AG have taken suitable technical and organisational measures to guarantee the security of personal data in compliance with articles 32-36 GDPR.
All the data you enter in our online shop will be passed to us by our order processor D&G and the subcontractor involved. The data is processed depending on order type as earmarked.

Same includes

  • performing the contract of sale after ordering from our online shop
  • creating a customer account on registration
  • making and terminating a newsletter subscription
  • transmitting the content of the contact form
  • catalogue orders

The legal basis for processing your data to perform a contract of sale is article 6, paragraph 1 lit. b GDPR. In all other cases mentioned above explicit agreement is required and article 6, paragraph 1 lit. a GDPR is hence then the legal basis for doing so.
All other data collected during any visit to our online shop without same being expressly entered (see 4.3.2 herein) will be transmitted anonymised and not saved together with personal data. This ensures that no conclusion on any specific natural person can be drawn therefrom.
Technical logs containing an IP address are kept for a maximum of six months for evaluation and detection purposes and support of investigative authorities concerning criminal activities. Events of significance to data protection are kept in central data protection log files for a maximum duration of one year.
All data collected via the online shop are saved as the law requires and then automatically erased.
You always have the option of having your personal data blocked and anonymised insofar as we no longer require it to meet contractual or legal obligations (e.g. performance of a contract of sale) and the law does not dictate otherwise. To raise an objection please contact our data protection officer
by e-mail at privacy@kramer.co.uk

or

by post
Kramer Equestrian Ltd.
Woodview Road
Paignton
Devon
TQ4 7SR
Great Britain

Please mark for the attention of the data protection officer.

5.2. Payment Options
5.2.1. Credit/Debit Card Payment

If you decide to pay for an order by credit/debit card then it will be debited using a PayGate payment form from

Computop GmbH
Schwarzenbergstrasse 4
96050 Bamberg
Germany


Computop GmbH, hereinafter called "Computop", is an enterprise that markets software for banks and leading service providers that ensures safe and secure financial transactions. As a partner of the banking business, Computop is regularly security audited to make sure your online payment/s is/are safe and secure.

The following data is recorded and sent Computop if you use this payment method:

  • card type (VISA or MasterCard)
  • name of card holder
  • card number
  • card verification code (CVC)
  • credit/debit card expiry date

This information can be saved subject to your agreement so that you do not have to repeat it for every order. To ensure your credit/debit card data is as safe and secure as possible we do not save it ourselves but have it saved in encoded form by Computop.
Computop makes an individual pseudo number available to us for every credit/debit card you use, which they save. This number includes only the three last numbers of your real credit/debit card. This enables us to debit the credit/debit card you last used for payment purposes next time you order from our online shop using this payment mode without us having to save the full number of your credit/debit card or Computop having to transmit this full number to us for that purpose. You only need to enter the CVC, which is then sent to Computop. This procedure contributes to the safety and security of your credit/debit card data and meets the PCI DSS (Payment Card Industry Data Security Standard) requirements. If you choose credit/debit card payment we only send the pseudo card number and CVC in encoded form to Computop and they can then identify the correct card in their system.
The purpose of credit/debit card payment via our service company Computop is to ensure your personal data and payment information is protected to the highest security standards. The legal basis for transmitting your data to Computop is article 6 paragraph 1 lit. f GDPR.
By paying by credit/debit card you agree to your personal data being sent Computop. The data is automatically erased from their systems by Computop after 24 months.
You may object to your data being processed when buying per credit/debit card and to the associated transmission of your payment information to Computop at any time. Just send us your written objection
by e-mail to privacy@kramer.co.uk

or

by post to
Kramer Equestrian Ltd.
Woodview Road
Paignton
Devon
TQ4 7SR
Great Britain

marked for the attention of the data protection officer.

Please note that such objection means you cannot use the payment by credit/debit card option any more.

5.2.2. Google Pay

If you choose the "Google Pay" payment method from Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland ("Google"), payment will be processed via the "Google Pay" app on your mobile device. The transmission of your data to GooglePay is based on Art. 6 para. 1 lit. a GDPR (consent) and Art. 6 para. 1 lit. b GDPR (processing for the fulfilment of a contract).

The following data is transmitted to Google for the purpose of payment processing in accordance with Art. 6 para. 1 lit. b GDPR

  • Date and time of the purchase
  • Amount of the transaction
  • Merchant location and description
  • A description of the purchased products provided by the seller
  • Name and email address of the seller
  • Name and email address of the buyer
  • The payment method used

For transactions via Google Pay, Google acts as an intermediary for processing the payment process between our website and the payment methods stored in Google Pay. Google transmits your payment information stored in Google Pay to our website in the form of a unique transaction number.This transaction number is created as a unique numerical token, which means that the transaction number does not contain any information about the real payment data of your means of payment stored with Google Pay.

Google reserves the right to collect, store and analyse certain transaction-specific information for each transaction made via Google Pay. This includes the date, time and amount of the transaction, merchant location and description, a description of the goods or services purchased provided by the merchant, photos that you have attached to the transaction, the name and email address of the seller and buyer or the sender and recipient, the payment method used, your description of the reason for the transaction and, if applicable, the offer associated with the transaction.

The data protection information for the use of Google Pay can be found here.

5.2.3. Apple Pay

If you choose the "Apple Pay" payment method from Apple Distribution International (Apple), Hollyhill Industrial Estate, Hollyhill, Cork, Ireland, payment will be processed via the "Apple Pay" function of your mobile device by charging a payment card stored with "Apple Pay". The transmission of your data to Apple Pay is based on Art. 6 para. 1 lit. a GDPR (consent) and Art. 6 para. 1 lit. b GDPR (processing for the fulfilment of a contract).

For the purpose of payment processing, the information you provide during the ordering process, along with information about your order, is forwarded to Apple in encrypted form. Apple then encrypts this data again with a developer-specific key before the data is transmitted to the payment service provider of the payment card stored in Apple Pay to process the payment. The encryption ensures that only the website through which the purchase was made can access the payment data. After the payment has been made, Apple sends your device account number and a transaction-specific, dynamic security code to the source website to confirm the success of the payment.

If personal data is processed during the described transfers, the processing is carried out exclusively for the purpose of payment processing in accordance with Art. 6 para. 1 lit. b GDPR.

Apple stores anonymised transaction data, including the approximate purchase amount, the approximate date and time and whether the transaction was successfully completed. This anonymisation completely excludes any personal reference. Apple uses the anonymised data to improve Apple Pay and other Apple products and services.

You can find further information on data protection at Apple Pay here.

5.3. Evaluations

If you purchase anything from our online shop you will be sent an e-mail some weeks later asking for your views on the shopping experience and the product/s bought. This is of course entirely voluntary.
To give our customers the option of submitting evaluations to a neutral independent platform and offer them access to anonymous customer evaluations on our website that may be useful in making a decision to buy our products we send the data to the evaluation platform:

eKomi Ltd.
Markgrafenstrasse 11
10969 Berlin
Germany

The following data is sent to EKomi, Ltd., hereinafter called "EKomi":

  • e-mail address
  • first name, last name
  • order number
  • order date
  • product/s chosen
  • customer evaluations
  • IP address

EKomi processes and uses the data solely for the purpose of evaluation handling.

They take the following measures to make customer and product evaluations available:

  • generation of evaluations by transmitting independent e-mails on the subject
  • acting as moderator of evaluations
  • providing marketing services
  • providing reputation management
  • collecting, analysing and processing data

The legal basis for using your data here is article 6 paragraph 1 lit. f GDPR and consideration of the processing reasons aforementioned.
To provide our customers with a treasure trove of customer and product evaluations long term, the relevant data is first erased when an order has been completely processed between us and EKomi.
You may object to the processing of evaluation e-mails as part of the handling of any order of yours by sending your objection to us
by e-mail at privacy@kramer.co.uk

or

by post
Kramer Equestrian Ltd.
Woodview Road
Paignton
Devon
TQ4 7SR
Great Britain

Please mark for the attention of the data protection officer.

Please note that in this case, any kind of e-mail notifications and thus automatic dispatch confirmations etc. will be discontinued.

5.4. Advertising
5.4.1 Dispatch of postal advertising

For the dispatch of our postal advertising, we work together with mail shops that handle the advertising mailings. For the purpose of personalised customer advertising and order processing, the following data is passed on to the commissioned lettershop:

  • first and last names
  • form of address
  • address

For the scope and purpose of the processing of personal data within the process of our postal advertising mailings, please refer to item Postal Advertising 4.3.6.2. The transmitted personal data will be deleted immediately after completion of the order with the respective supplier.

5.4.2 Sending push notifications

You can register to receive so-called push notifications. For this purpose, we use the "CleverPush" offer, which is provided by the

CleverPush GmbH
Nagelsweg 22
20097 Hamburg
- hereinafter referred to as "CleverPush".

You will receive regular information and reminders about our push notifications:

- discount promotions and events in our online shop
- the dispatch of our biannual print catalogues
- items that are still in your shopping cart after a session has expired (so-called "shopping cart abandoners")
- the shipping status of your orders To sign up for the push notifications, you must confirm your browser or device's request to receive the notifications. This process is documented and stored by CleverPush.
The following data is collected by CleverPush for this purpose:
- the login time
- a push token or device ID

This data is used on the one hand to be able to send you the push notifications and on the other hand as proof of your registration. The legal basis for this processing is your consent and thus Art. 6 para. 1 lit. a GDPR.

CleverPush also evaluates our push notifications statistically. CleverPush can thus identify if and when our push notifications were displayed and clicked on. This enables us to determine which push notifications interest the recipients in order to adjust future messages to the presumed interests of all recipients and thus increase interest in our offer. Additionally, in addition to the push token or device ID, we store the subject focus of the app on which the push notifications were activated (e.g. business, sports, etc.). We also use this information to send push notifications to the relevant subscribers that are in their presumed interests. The legal basis of the processing in each case is Art. 6 para. 1 lit. f GDPR. The assignment of a push token or device ID to a specific person only takes place if we should be legally obliged to do so, for the defence of claims against us if this is required as evidence, as well as for the possible prosecution of violations of the law. You can revoke your consent to the storage and use of your personal data to receive our push notifications at any time with effect for the future. Furthermore, you can object to the use of personal data described above on the basis of Art. 6 para. 1 lit. f at any time. Please revoke your consent for this purpose. You can revoke your consent in the settings provided for this purpose for receiving push notifications in the settings of your device or browser. Your data will be deleted as soon as it is no longer required to achieve the purpose for which it was collected. Your data will therefore be stored as long as the subscription to our push notifications is active.

The following link explains the unsubscription process in detail:
 https://cleverpush.com/faq.
To speed up the retrieval of content (e.g. images) and to defend against attacks, CleverPush uses cloudflare.com, an offering of Cloudflare, Inc. as part of a commissioned processing based on the standard contractual clauses.

CleverPush does not store any data on Cloudflare's servers that contain personal data, but only general content such as texts or images. When you call up this content, the end device you are using establishes a connection to Cloudflare and the IP address of the end device you are using is processed as a result.

5.5. Parcel Service and Shipping and Forwarding Agent

We work as a rule with the parcel service and shipping and forwarding agent UPS:

UPS Europe SPRL/BVBA
Avenue Ariane 5
1200 Brussels
Belgium
tel.: 3457877877

Use of UPS's goods and services is essential to perform the contract of sale with us and send you the goods you ordered.

The following data is sent UPS in the process:

  • first and last names
  • shipping address

UPS needs the name, first name and shipping address to deliver the goods in question. We therefore consider the data transmission to UPS to be justified within the meaning of article 6 paragraph 1 lit. b GDPR.
As rendering postal goods and services does not constitute processing orders within the meaning of article 28 GDPR, UPS is considered an independent responsible legal person needing to process sender and addressee addresses and contract and delivery data in order to render said postal goods and services.
UPS is subject to specific obligations where postal confidentiality and particularly data protection law are concerned. The data protection management of the UPS Europe SA Group complies with the GDPR.
You may consult the responsible data protection officer of UPS on all matters concerning personal data processing by the UPS Europe SA Group as an independent responsible legal person:

UPS Europe SA
Attention: Global Privacy Manager
Ave Ariane 5
Brussels, 1200
Belgium

5.6. On-Site Search

For Product Discovery, in particular search and navigation, we use the services of Findologic GmbH, Jakob-Haringer-Str. 5a, 5020 Salzburg, a technology company, which attempts by data analyses to cater for personal needs and preferences.
Cookies are used for the storage of information about the website users and various data are transmitted to the service provider, these in particular comprise the IP address and browser identification of the users, as well as thus associated behavioural data such as search queries, visited categories, selected filters, viewed and purchased products.
This helps us understand which products are most interesting for our users and to optimise the shopping experience for this purpose.

The legal basis for using your data here is article 6 paragraph 1 lit. f GDPR and consideration of the processing reasons aforementioned.

A contract for data processing was concluded with Findologic.

5.7. Conversion tracking with Google Ads

We use Google Ads to draw attention to our offers with the help of advertisements in Google search results.
We use the following forms of ad placement:

  • Google Shopping ads
  • Sponsored Ads (text ads that appear at the top of the search results)
This is a service provided by:
Google Ireland Limited
Gordon House
Barrow Street
Dublin 4
Ireland
- hereinafter referred to as Google -
In order to comply with data protection regulations, the consent for the conversion tracking function in Google Ads is integrated in the cookie settings under the functional cookies. Only if you agree to the data processing in the context of our cookie banner and the addition of the functional cookies using the opt-in procedure will the conversion made on our website be transmitted to Google Ads using the Google Tag Manager (see point 5.9) to improve our ads. If you do not consent to the use of functional cookies, the information about your visit will be discarded.

As soon as you reach our website via one of the aforementioned Google ads placed by us, a connection to the Google servers is established and a cookie with a lifespan of 30 days is set, which, to the best of our knowledge, collects the following data:
  • Date and time of the visit to the website
  • Anonymized IP address
  • Advertisement from which you reached our website
  • Whether a purchase takes place
It cannot be ruled out that Google uses servers in the USA.
The legal basis for the integration of conversion tracking for Google Ads / Google Shopping is Art. 6 para. 1 lit. a GDPR, as consent to the processing of the aforementioned data has been given by confirming the functional cookies.

Further information on the data protection provisions and terms of use of Google products can be found in the Google Terms of Use.
You can revoke your consent at any time via the cookie settings .

In order to be able to present you with advertisements that are relevant to you, we use Google Tag Manager from Google in connection with Google Ads.
This is a service provided by:
Google Ireland Limited
Gordon House
Barrow Street
Dublin 4
Ireland

and Google LLC:
1600 Amphitheatre Parkway
Mountain View
CA 94043
USA
- hereinafter referred to as Google for short -
order to comply with data protection regulations, the consent for the Google Tag Manager function is integrated in the cookie settings under the functional cookies. The Google Tag Manager is only activated if you agree to the data processing in the context of our cookie banner and the addition of the functional cookies by means of an opt-in procedure.

The Google Tag Manager itself does not set any cookies, but acts as an administrator of the tags set in other Google products - in our case Google Ads - and passes them on to the corresponding Google products. The Google Tag Manager itself does not access this data.

The legal basis for the integration of the Google Tag Manager is Art. 6 para. 1 lit. a GDPR, as consent to the processing of the aforementioned data has been given by confirming the functional cookies.

Further information on the data protection provisions and terms of use of Google products can be found in the Google Terms of Use. You can revoke your consent at any time via the cookie settings.

6. Cookies

Our website uses cookies. More details on cookies and their use on our websites are given in the section that follows.

6.1. What are cookies?

A cookie is a small text file (up to 4KB) created by a website that is stored in the user's computer, either temporarily for that session only, or permanently on the hard disk. Cookies provide a way for the website to recognise you and keep track of your preferences. Cookies may be stored every time you access a website on the Internet. They contain text files identifying the browser when it is used to access a website again.

There are two different kinds of cookies, as below.

  • Session cookies
    These are erased once the browser is closed and hence are only valid for a single session, as the name suggests. As a rule they are used for purely technical reasons, e.g. to ensure the shopping basket function applies over several pages and that the products placed therein during shopping are retained.
  • Permanent cookies
    Permanent cookies are stored on your hard disc for a lengthy period to make your use of our site easier. Permanent cookies ensure your browser remembers the products in a shopping basket for days or even weeks so that you can continue shopping where you left off. Permanent cookies each have an expiry date which may be days or possibly years in the future.
6.2. What do we use cookies for?

Cookies are used to make your use of our online shop as simple as possible. For technical reasons some functions of our online shop require the browser to be identifiable after a change of page.

To safeguard the functions of our online shop we use the following cookies:

  • Shop management cookies
    These are created in our online shop and include secure cookies that protect data of data protection significance in SSL (Secure Sockets Layer) code. Shop management cookies are erased automatically when the browser is closed.
  • Detection of cookie support
    When you access our online shop the website checks whether your browser accepts cookies. This cookie has a service life of two years unless erased earlier by your browser settings.
  • Shopping basket function
    To make sure the content of your shopping basket is retained for more than a single visit the necessary information is saved in a cookie. These cookies have a service life of thirty days.
  • Welcome Back function
    This function displays a welcome message to registered customers visiting our online shop. This is shown immediately you call up the site before you log in.
  • Redirect information
    This cookie is generated if a product or category is no longer available in our online shop and you are therefore sent on to the next higher category or the home page. This cookie contains the information that the page no longer exists and is erased the next time it is called up. If it is not called up again then it is erased after thirty days at the latest.

We also use cookies enabling us to analyse the surfing behaviour of visitors.

The following data can thus be sent:

  • number of page hits
  • products and categories viewed
  • duration of shop viewing
  • search activity
  • information on the mobile device used (type, operating system and version)
  • imprecise location data from the abbreviated IP address

The cookie data collected for analysis use is anonymised using technical means so that no natural person can be identified. This data is never saved together with other personal data.
If you visit our online shop an information banner opens telling you cookies are being used and drawing your attention to our data protection declaration. 6.3 herein contains information on how to prevent cookies being saved in your browser settings.
The legal basis for processing personal data using cookies is article 6 paragraph 1 lit. f GDPR.
Technically essential cookies make the use of our online shop simpler. Many functions normally integrated in online shops such as saving articles from more than one page in the same shopping basket require the use of cookies. It is hence often necessary that a browser be identified even after a page change.
Cookies are needed in the online shop for the following applications:

  • secure cookies so that content of data protection significance can be transmitted safely
  • detection of cookie use
  • retention of a shopping basket over more than one session or device
  • copying language settings
  • making login information available
  • generating personalised welcome messages
  • automatic redirection if any product or category is not available

The user data generated by technically essential cookies is not used to draft user profiles.
Use of analysis cookies has the purpose of constantly improving our online shop and your shopping experience. These cookies give us an insight of how our online shop is used, allowing us to take any measures needed to optimise the site.
These purposes constitute our legitimate interest in the processing of personal data pursuant to article 6 paragraph 1 lit. f GDPR.
Our analysis cookies generated by our service provider Econda do not include personal data. The data recorded is anonymised and does not permit any conclusion as to the identity of any natural person. More information on Econda analysis cookies is given in 8 below.

Cookies are saved on your device’s hard disc by your Internet browser and sent to us by same. As user you have full control of the use of cookies and can manage them by yourself. You can erase saved cookies at any time with the aid of your browser settings. You can also use your browser to control the use of cookies by permitting or blocking them, permitting only cookies from specific web sites to be used or blocked or having cookies automatically erased after every browser session. More information on cookie management is given in the help file of your browser.

Please note that deactivating cookies may mean that not all functions of our online shop can be fully used.

Always active
These cookies & technologies are necessary for our website to function and cannot be disabled at this point. They are basic cookies that allow our website to function properly so that you can use the most important functions, such as adding items to your shopping cart or logging in, and navigating the website without any problems.
These cookies & technologies enable improved functionality and personalisation. They are set by us or our web analytics partner econda GmbH, whose services we use on our pages. If you disable these cookies & technologies, the functionality of these or all services may be limited. These cookies enable us to count visits and access sources so that we can measure the performance of our website and optimise it accordingly. Based on the information you leave, we can identify the most popular shop pages and in turn improve under-used pages in the visitor's interest. All information collected by these cookies is aggregated and therefore anonymous. If you do not allow these cookies, we will not be able to know when and from where you visited our website.

Cookies are also included, which are necessary for the placement of cross-website advertisements in Google search results in the form of Google Ads. You can find more information here.
With our "comfort functions" you give us permission to use reCAPTCHA, which protects our website from malicious software and bots. The comfort functions uses your browser interactions to determine that you are human. This eliminates the need for you to complete a traditional CAPTCHA before using our website. You can revoke your consent at any time via our privacy policy.
7. Analysis Tools

We use web analysis tools to constantly improve our online shop and your shopping experience. Which tools we use and whether and which personal data they record and what use they make thereof is explained below.

7.1. Econda

To tailor and optimise our website we utilise the goods and services of

Econda GmbH
Zimmerstr. 6
76137 Karlsruhe
Germany

hereinafter called "Econda". Said goods and services collect anonymised data and save it to generate user profiles employing pseudonyms.
Cookies may be used to do so, that recognise repeated use of any browser. User profiles are not merged with data on any bearer of any pseudonym without the agreement of the visitor in each and every case. IP addresses in particular are made unrecognisable on receipt, making assignment of user profiles to IP addresses impossible.
Econda cookies are used to constantly improve our online shop and your shopping experience. These cookies give us an insight of how our online shop is used, allowing us to take any measures needed to optimise the site.
These purposes constitute our legitimate interest in the processing of personal data pursuant to article 6 paragraph 1 lit. f GDPR.
We also use data collected by Econda to send you your personalised newsletter. If you visit our online shop as a logged in customer with a newsletter subscription you may be sent personalised product recommendations by e-mail. This is the case if you put products in your shopping basket without purchasing them. This is not the case if you are a guest visiting our online shop.
If so Econda assigns your shopping basket an anonymised identification number that does not permit any conclusions on your person or identity. Said number is linked by us to your e-mail address so that we can send you your newsletter.
The legal basis for this form of data recording - which Econda does on an anonymised basis for direct advertising purposes - is article 6 paragraph 1 lit. f GDPR, making all due regard for recital 47 of the GDPR.
The Econda analysis tool saves the anonymised data it is sent by employing the methods below. IP addresses of website visitors are briefly cached for 2-5 minutes before being masked for handover to the analysis process. Log files are compressed after three days and completely erased after thirty. All other data is saved for the duration of the order processing contract between us and Econda.
Visitors of Kramer Equestrian can deactivate this form of data recording and saving by setting opt out cookies. Please note that such deactivation only applies to the device and web browser used; please repeat the procedure for each of any other devices. Once you erase the opt out cookie enquiries will again be sent to Econda.

8. Protection of Personal Data

We take a personal interest in protecting your data as we want you to enjoy visiting our online shop.
State-of-the-art technical and organisational measures are taken to ensure your data is safe. An example of this is the encoded transmission of your data using SSL encoding in our online shop. This ensures that unauthorised persons cannot view or change it.
Our safety and security measures are oriented on article 5 paragraph 1 lit. f GDPR, article 32 paragraph 1 GDPR and all the other data protection requirements in the GDPR.
Our data protection officer will gladly inform you comprehensively of the technical and organisational measures we take to protect your personal data. Please contact our data protection officer
by e-mail at privacy@kramer.co.uk

or

by post
Kramer Equestrian Ltd.
Woodview Road
Paignton
Devon
TQ4 7SR
Great Britain

Please mark for the attention of the data protection officer.

9. Rights of Data Subjects

If your personal data is processed, you are a data subject within the meaning of the GDPR and you have the rights below with respect to Kramer Equestrian.

9.1. Right of Access

You can request us to confirm whether we process personal data that concerns you. If so then you are entitled to the following information:

  • the purpose of said processing
  • which data is processed
  • who receives same and why it is passed on
  • how long the data is saved and the reason for that duration
  • the existence of a right of rectification or erasure of personal data that concerns you, of restriction of processing by us and of a right to object to such processing
  • the existence of a right of objection to a supervisory authority
  • the origin of the data if not transmitted by you

You have the right to demand information on whether the personal data in question will be sent to a third country or an international organisation. In this context you may demand you be informed of suitable guarantees per article 46 GDPR where such transmission is concerned.

9.2. The Right of Rectification

You have a right of rectification and/or completion with respect to Kramer Equestrian if the personal data processed concerning you is incorrect or incomplete. We will carry out any such rectification immediately.

9.3. Right to Restriction of Processing

You have the right to demand restriction of the processing of data concerning you under the condition/s below.

  • You dispute the accuracy of the personal data concerning you for a period of time that enables the responsible party to verify the accuracy of the personal data.
  • The processing is unlawful and you reject erasure of the data and instead request that the use of the data be restricted.
  • We do not need the data any longer for processing but you need it for the assertion, exercise or defence of legal claims.
  • If you have objected to processing per article 21 paragraph 1 GDPR and it is not yet certain whether our justified reasons outweigh yours.

Where processing of the personal data that concerns you has been restricted, such data - apart from being stored - may be processed only with your consent or for the purpose of asserting, exercising or defending rights or protecting the rights of another natural or legal person or on the grounds of an important public interest of the Union or of a Member State.

If the processing restriction has been restricted in accordance with the condition/s above you will be informed by the responsible party before the restriction is lifted.

9.4. Right to Erasure
9.4.1 Erasure Obligation

You have the right to request the erasure of data concerning you. Kramer Equestrian is obliged to erase said data, provided any of the following reasons apply:

  • the data that concerns you is no longer necessary for the purpose/s for which it was collected or processed.
  • You revoke your consent to the processing pursuant to article 6 paragraph 1 lit. a GDPR or article 9 paragraph 2 lit. a GDPR and there is no other legal basis for the processing.
  • You object pursuant to article 21 paragraph 1 GDPR to the processing and there are no overriding justified grounds for the processing, or you submit an objection according to article 21 paragraph 2.
  • The data concerning you has been illegally processed.
  • The erasure of the data concerning you is required to fulfil a legal obligation according to Union law or the law of a Member State to which we are subject.
  • The data concerning you has been collected in relation to services offered by the information company pursuant to article 8 paragraph 1 GDPR.
9.4.2 Information to third parties

If we publicised data concerning you and are now obliged to erase same per article 17 paragraph 1 of the GDPR then we must take appropriate measures, including technical ones making all due allowance for available technology and implementation costs, to inform the parties responsible for data processing who process the personal data that you, as the person concerned have requested erasure of all links to said personal data and of copies and replications of same.

9.4.3 Exceptions

The right to erasure does not exist insofar as the processing is necessary

  • to fulfil a legal obligation in Union law or that of any Member State to which we are subject, and/or
  • to assert, exercise or defend legal claims.
9.5. Right of Information

If you have exercised your right to have us correct, erase or limit the processing then we are obliged to inform all recipients, to whom the personal data that concerns you has been disclosed, of this correction, erasure or limitation of processing of the data unless this proves impossible or involves disproportionate effort and/or cost.

You have the right to oblige us to inform you regarding such recipients.

9.6. Right to Data Portability

You have the right to receive the personal data you provided us with in a structured, conventional and machine-readable format. You also have the right to pass this data on to another responsible party without obstruction by us as the responsible party to whom the personal data was originally provided, insofar as

  • the processing is on the basis of consent per article 6 paragraph 1 lit. a GDPR or article 9 paragraph 2 lit. a GDPR or a contract per article 6 paragraph 1 lit. b GDPR and
  • the processing is rendered with the aid of (an) automated procedure/s.

In exercising this right you also have the right to ensure that the personal data concerning you be transferred directly from one responsible party to another responsible party insofar as this is technically feasible. The liberties and rights of other persons may not be affected by this.
The right to data portability does not apply to the processing of personal data necessary for the performance of a task in the public interest or in the exercise of official authority conferred on us.

9.7. Right to object

You have the right, for reasons arising from your specific situation, to object at any time to the processing of personal data concerning you that is carried out in accordance with article 6 paragraph 1 lit. e GDPR.
We will then cease to process the personal data that concerns you unless we can prove compelling reasons worthy of protection for the processing that outweigh your interests, rights and liberties, or the processing serves to assert, exercise or defend any legal claim.
If the personal data that concerns you is processed for direct marketing purposes you have the right to object at any time to the processing thereof for said purposes; this also applies to profiling, insofar as same is associated with such direct marketing.
If you object to processing for direct marketing purposes then the personal data that concerns you will no longer be processed for such purposes.
You have the option of exercising your right of objection in connection with the use of information company services by means of automated procedures using technical specifications, notwithstanding Directive 2002/58/EC.

9.8. The Right to revoke the Data Protection Declaration of Consent

You have the right at any time to revoke your data protection declaration of consent. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its revocation.

9.9. Who must I contact to assert my Rights as an affected Person / Data subject?

To assert your rights as an affected person / data subject to information on the collection, processing and use of your personal data and to have same rectified or erased please contact our data protection officer
by e-mail at privacy@kramer.co.uk

or

by post
Kramer Equestrian Ltd.
Woodview Road
Paignton
Devon
TQ4 7SR
Great Britain

Please mark for the attention of the data protection officer. Our officer will deal with the matter promptly.

9.10. Right to complain to a supervisory authority

Without prejudice to any other administrative law or judicial remedy, you have the right of appeal to a supervisory authority, in particular in the Member State where you reside, work or where the infringement is suspected, if you believe that the processing of personal data that concerns you is in contravention of GDPR.
That supervisory authority shall inform the complainant of the status and result of the complaint, including the possibility of a judicial remedy under article 78 GDPR.

The supervisory authority responsible here is the

Information Comissioner's Office
Wyclyif House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Phone: 0303 123 1113
E-mail: dataprotectionfee@ico.org.uk
Website www.ico.org.uk