Privacy Policy – Se’tyo

 

We take the safety of your privacy seriously. This is why we have a special focus on safety of your personal data. Formulations like “us” or “we” refer in all cases to the named responsible persons and to Se’tyo e.K. within this policy. This privacy policy does explain, how we use and process your data.

Last update: May 9, 2025

 

1. Responsible person in terms of data protection regulations

Se’tyo e.K.
owner: Melanie Moosbrugger (Ruka Akimori)
Luppenstraße 26
04177 Leipzig, Germany

Telephone: +49-176-99936836
E-Mail: contact@setyo.de

 

2. Data Protection officer

Unspecified, see above

 

3. Scope and legal basis for processing of personal data, duration, storage and deletion of data

We protect our systems through technical and organizational measures against unauthorized access, modification, distribution or destruction by unauthorized third parties. To protect data transmission on the website, we use SSL encryption. You can recognize this by the prefix https:// in the address line of your browser.

 

a. Data collection on our website

You can visit our website at any time without disclosing your name. However, when you access the website, data about this process is temporarily stored on our provider’s server in a log file, a type of protocol. Our providers process our data to display the website and for hosting. The following data is stored:

• Your current IP address and your Internet service provider
• Date and time of accessing our website
• Websites that you as a user access from our website, or from which you have reached our website
• Information about the type and version of your browser and your operating system

The creation of user profiles with personal reference is excluded.

The data collection serves the sole purpose of ensuring a smooth connection and use of the website, as well as better user comfort. Legal basis for this is Article 6 Paragraph 1 Section a of the GDPR (DSGVO). Our legitimate interest arises from economic considerations in order to make our website available to users and to make it more convenient.

All data is deleted after the purpose of its collection has been achieved, no later than 7 days.

 

b. Cookies

We use so-called cookies on our website. These are small text files that are stored on your device. This storage generates the collection and processing of user information, in particular IP addresses and browser settings.

We use session cookies and transient cookies. These are deleted as soon as you close your browser. We need these cookies so that your shopping cart can be displayed correctly in the online shop and your login status is also displayed correctly. The cookies store so-called session IDs, which can be assigned to a request from your browser and the shared session.

You can set your browser at any time so that cookies are not set without your knowledge; you can also allow or reject cookies individually. For more information, refer to your browser’s menu under “Cookie Settings.” However, rejecting cookies may result in functions being restricted or our website not being usable properly.

The purpose of setting cookies is to make our website and offers attractive for users and for you, and to determine and optimize the reach and positioning of the website, for example, on Google. The legal basis for this is Article 6, Paragraph 1, Section f of the GDPR. Our legitimate interest arises from economic considerations, for the stated purpose of cookies to provide the best possible offers.

 

c. Google Analytics

We use Google Analytics on our website. This is a web analysis service provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, hereinafter referred to as “Google.” Google uses these text files (cookies) and stores them in your browser. This generates information about your use of our website and transmits it to a Google server. We have activated IP anonymization for the use of Google Analytics. This means that the IP address of users of our website within the contracting states of the Agreement on the European Economic Area and in member states of the European Union is shortened. A full transmission of the IP address to a Google server in the USA only occurs in exceptional cases and is then stored and shortened there.

Google is certified under the Privacy Shield Agreement. This guarantees compliance with European data protection law. You can find more information about this here:
https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active

Google will use the transmitted information as commissioned. This contract is to evaluate the use of our website, compile reports on website activity, and provide us with other services related to website activity and internet usage. This may result in the creation of pseudonymous user profiles, although the IP address transmitted by your browser will not be merged with other Google data.

You can configure your browser at any time to prevent cookies from being set without your knowledge. You can also allow or reject cookies individually. For more information, see your browser’s menu under “Cookie Settings.” However, rejecting cookies may result in limited functionality or our website not being usable properly.

You also have the option of preventing the collection of data generated by the cookie and related to your usage, as well as its transmission to Google and its processing by Google. To do so, you can download and install the following browser plug-in:
http://tools.google.com/dlpage/gaoptout?hl=de.

You can also find more information on the following pages:
https://policies.google.com/technologies/partner-sites

http://www.google.com/policies/technologies/ads

http://www.google.de/settings/ads

https://policies.google.com/privacy

https://support.google.com/analytics/answer/6004245?hl=en&sjid=3995225087659594924-EU

The purpose of using Google Analytics is to make our website and offerings more attractive for users and for you, and to determine and optimize the reach and positioning of the website on Google. The legal basis for the use and temporary storage of data is Article 6, Paragraph 1, Section f of the GDPR. Our legitimate interest arises from economic considerations, for the stated purpose of using the analysis tools. The data will be deleted when it is no longer needed for analysis, but no later than after 14 months.

 

d. Contact by E-Mail

You can contact us by voluntarily using the email addresses and contact form provided. If you wish to contact us in this way, we will process your email address and the personal data you send via the contact form or email. Depending on what you enter, such data may include your name or telephone number in addition to your email address, but this also applies to all other data sent. You contact us voluntarily by email or contact form. Without providing and processing your personal data, a conversation with you is not possible. However, the data will only be used for the purpose of processing your request. It will only be passed on to third parties with your consent.

The legal basis for processing data when sending an email or using the contact form is Article 6 Paragraph 1 Section a of the GDPR (DSGVO). Our legitimate interest arises from being able to process your request. If the request is aimed at concluding a contract, the legal basis is Article 6 Paragraph 1 Section b of the GDPR (DSGVO). It is also necessary for us to process the data in accordance with Article 6 Paragraph 1 Section c of the GDPR (DSGVO) in order to comply with our obligations under tax law, particularly with regard to retention obligations. Furthermore, in accordance with Article 6 Paragraph 1 Section f of the GDPR (DSGVO), we may retain your data beyond the statutory retention periods after contract fulfillment in order to be able to defend ourselves against the assertion of claims. If you consent to the processing operations, the legal basis is Article 6 Paragraph 1 Section a of the GDPR (DSGVO).

If the request is made regarding the conclusion of a contract, we will provide further information on the processing of personal data.

If the data is not required to be stored for a longer period due to retention and documentation obligations under tax or commercial law, such as the German Commercial Code (HGB), the German Criminal Code (StGB) or the German Fiscal Code (AO), we will delete the data after the request has been processed. Storage under the German Commercial Code (HGB), the German Criminal Code (StGB) or the German Fiscal Code is generally required for 10 years. In exceptional cases, data may be stored for up to 30 years if this is necessary to preserve evidence for the period during which claims can be asserted against us.

 

e. Contact by Messenger- Functions in Social Media

As an alternative to emails, we offer contact via the chat function of social media and via messenger services. We use the social media Facebook and Instagram, among others, as well as the services LINE and WhatsApp, but the same conditions apply to all other services.

You can contact us voluntarily using the options provided. If you wish to contact us in this way, we will process the personal data you send us. Depending on what you enter, such data may include your name or account name in addition to your email address, but this also applies to all other data sent. You contact us via messenger services voluntarily. Without providing and processing your personal data, a conversation with you is not possible. However, the data will only be used for the purpose of processing the request. It will only be passed on to third parties with your consent.

The legal basis for processing data when sending such a message is Article 6 Paragraph 1 Section a of the GDPR (DSGVO). Our legitimate interest arises from being able to process your request. A contract is not concluded in this way, but only via email or the online shop.

Unless the data is required to be stored for a longer period due to tax or commercial law retention and documentation obligations, such as those under the German Commercial Code (HGB), the German Criminal Code (StGB) or the German Fiscal Code (AO), we delete the data after the request has been processed. Storage under the German Commercial Code (HGB), the German Criminal Code (StGB) or the German Fiscal Code is generally required for 10 years. In exceptional cases, data can be stored for up to 30 years if this is necessary to preserve evidence for the period in which claims can be made against us.

 

f. Registration

You can voluntarily register on our website and open a customer account. The data you enter there and therefore provide to us will be processed by us. Your email address and a password are mandatory. Optional data includes name, address, company, VAT ID, and telephone number.

The purpose of collecting this data is to enable us to manage your customer account and simplify the ordering process in the future. The data in your customer account will not be shared with third parties. The legal basis for processing this data is Article 6 (1) (b) of the GDPR. Since we also obtain your consent when creating your customer account, Article 6 (1) (a) of the GDPR also serves as the legal basis for this.

Our legitimate interest arises from maintaining your customer account. Your customer account will be deleted after you revoke your consent, unless we are obligated to retain it for a longer period due to retention and documentation obligations under tax and/or commercial law. Obligations may arise from the German Commercial Code (HGB), the German Criminal Code (StGB) or the German Fiscal Code (AO) and usually lead to longer storage periods, up to 10 years.

 

g. Newsletter

We offer a newsletter that can be ordered via our website. For this you must provide your email address. In the newsletter we inform you at irregular intervals about new products and designs as well as events. After you have registered on our website, you will receive an email to the address provided with a confirmation link. This link must be actively clicked in order to complete a final registration for the newsletter. This ensures that you have actually consented to receiving the newsletter and data processing (double opt-in procedure).

The email address provided, the date of registration and the confirmation are saved. The data will be deleted after you revoke your consent, which can be done at any time. Consent can also be revoked at any time at a later date. There is a link in the newsletter for this, or you can simply send us an email. A revocation only affects the subsequent period, but not the legality of the processing carried out before the time of revocation. The data will be deleted after revocation.

If the registration for the newsletter is not confirmed within 7 days, the data will also be deleted.

The legal basis for this storage of data is Article 6 Paragraph 1 Section a of the GDPR (DSGVO), as we obtain your consent. The purpose and legitimate interest of the data processing is the provision of the newsletter and its dispatch.

To send the newsletter, we use the services of Clever Elements GmbH, Mühlenstr. 8a 14167 Berlin, HRB 125967 B. A corresponding contract for order processing has been concluded with Clever Elements. The email addresses are processed there. Neither complete IP addresses nor cookies are used or processed to measure reach.

 

h. Ordering process and shipping

If an order is placed by email, contact form or website, personal data must be provided as part of the ordering process. This includes name, address, email address and, if applicable, telephone number.

We need this data for the purpose of contacting you in order to be able to fulfill our contractual obligations to you. This includes production, delivery, invoicing and any other claims that arise, for example, from the statutory obligations to tax and commercial retention obligations that we have to fulfill.

The legal basis for this storage of data is Article 6 Paragraph 1 Section b of the GDPR (DSGVO). If the data is not provided, the contract could not be concluded. It is also necessary for us to implement processing of the data in accordance with Article 6 Paragraph 1 Section c of the GDPR (DSGVO) in order to comply with our obligations under tax law, particularly with regard to retention obligations. Furthermore, in accordance with Article 6 Paragraph 1 Section f of the GDPR (DSGVO), we may retain your data beyond the statutory retention periods after contract fulfillment in order to be able to defend ourselves against the assertion of claims. If you agree to the processing operations, the legal basis is Article 6 Paragraph 1 Section a of the GDPR (DSGVO).

In the event of a request regarding the conclusion of a contract, we will provide further information on the processing of personal data.

In addition to the data mentioned, we also need further data from you for custom-made items. This includes, among other things, body measurements. We sometimes ask for extended personal information in the course of the design process using questionnaires. You provide us with all the information you provide in these questionnaires voluntarily. With the information, you help us to create a design that suits you and to meet your needs and wishes.

We need this data in order to create a convincing offer for you. We need your measurements so that we can manufacture your order in such a way that the clothing is tailored to you and fits you.

The legal basis for this storage of data is Article 6 Paragraph 1 Section b of the GDPR (DSGVO). If the data is not provided, the contract could not be concluded. If you agree to the processing operations, the legal basis is Article 6 Paragraph 1 Section a of the GDPR (DSGVO). The purpose of collecting this extended data is the proper preparation of an offer and the contractual production of articles for you. In the event of a request regarding the conclusion of a contract, we will be happy to provide further information on the processing of personal data.

If the data is not required to be stored for a longer period due to tax or commercial law retention and documentation obligations, such as those arising from the German Commercial Code (HGB), the German Criminal Code (StGB) or the German Fiscal Code (AO), we delete the data after the order has been completed. Storage according to the German Commercial Code (HGB), the German Criminal Code (StGB) or the German Fiscal Code is usually required for 10 years. In exceptional cases, data can be stored for up to 30 years if this is necessary to preserve evidence for the period in which claims can be asserted against us. If a contractual relationship is not established after a request for a quote, the personal data will be deleted accordingly.

In some cases, it is necessary for the contract to be fulfilled that your personal data is passed on to service providers. In all cases, the legal basis is Article 6 Paragraph 1 Section b of the GDPR (DSGVO). The purpose of the transfer is the mutual fulfillment of contractual obligations, such as the delivery of the goods or their payment. Furthermore, the transfer of personal data is sometimes necessary due to legal obligations to authorities (e.g. tax office). In addition, our tax office receives invoices to prepare the necessary steps for us. These invoices contain your data.

In order to ship the items, we pass on the necessary data to our shipping service providers. We work together with DHL Paket GmbH for this. Accordingly, we pass on your data to DHL Paket GmbH, Sträßchensweg 10; 53113 Bonn. In the case of special requests for shipping, it may be necessary to pass on your data to other shipping service providers in order to fulfill the contract. We only do this at your express request.

 

i. Payment processing

To process the payment, the commissioned credit institutions and payment service providers receive your data, depending on which one you choose:

 

PayPal:

If you have decided to pay with PayPal, we will pass on the data relevant to the order or order to PayPal (Europe) S.à.r.l. & Cie., S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg. This data includes, for example, first name, last name, address, email address, telephone number, IP address, number and type of items or services, item numbers, invoice amount, information on taxes and invoice information. We would like to point out that, in addition to an age check, PayPal also collects information on the buyer’s previous payment behavior. PayPal also uses this to calculate probability values ​​for future behavior and scoring values.

PayPal calculates these on the basis of scientifically recognized statistical and mathematical methods. PayPal also uses address data for this purpose. If PayPal calculates that your creditworthiness is not met, PayPal will inform you of this.

You can revoke your consent to the use of your personal data directly to PayPal, whereby PayPal may be entitled to use and transmit personal data for contractual payment processing and legal regulations. The privacy policy of PayPal (Europe) S.à.r.l. & Cie provides information on these topics: https://www.paypal.com/de/webapps/mpp/ua/privacy-full

 

4. Sensitive personal data

 We ask you not to disclose any sensitive personal data about yourself on our platforms or other channels, such as information about your origin and ethnicity, data about your sexual orientation or sex life, political opinions, religious beliefs, trade union membership, criminal record or similar information, unless such information is used for a justified purpose.

 

5. Your rights as a data subject

As a data subject, you have a number of rights that we would like to point out:

• Right of information: You have the right to receive precise, transparent and easily understandable information about how we use and process your personal data. You also have a right to information about what rights you have. That is why we provide you with the information in this privacy policy. (Art. 19 GDPR / DSGVO)
• Right of inquiry: You will receive information from us at any time about the personal data concerning you that we process (Art. 15 GDPR / DSGVO)
• Right of correction: If your personal data is incorrect, you have the right to have it rectified by us at any time (Art. 16 GDPR / DSGVO)
• Right of erasure: This right enables you to have your personal data erased by us, provided that no other legal circumstance prevents this (Art. 17 GDPR / DSGVO)
• Right of restriction of processing: You have the right to prohibit further processing of your personal data, although this will remain stored (Art. 18 GDPR / DSGVO)
• Right of data portability: You have the right to receive your data in a common, structured format and can request that it be transferred to another responsible party (Art. 20 GDPR / DSGVO)
• Right of objection: Under certain circumstances, you have the right to object to the processing of your personal data, including for certain purposes. Processing for other purposes then remains possible (Art. 21 GDPR / DSGVO)
• Right to complain to a supervisory authority: You have the right to complain to a supervisory authority about our processing of your personal data. (Art. 77 GDPR (DSGVO) in conjunction with Section 19 BDSG).

The German supervisory authority is:

The State Commissioner for Data Protection of Lower Saxony (Germany)

Prinzenstraße 5, 30159 Hannover, Germany

Telephone number: 0049-511 120 – 4500.

E-mail: poststelle@lfd.niedersachsen.de

Website: https://www.lfd.niedersachsen.de

To exercise your rights, contact us directly via contact@setyo.de

 

Right to object in accordance with Art. 21 GDPR (DSGVO)

Individual right of objection:

You have the right to object at any time to the processing of your personal data based on a balance of interests (Article 6 Paragraph 1 Section f of the GDPR / DSGVO) and on the basis of public interest (Article 6 Paragraph 1 Section e of the GDPR / DSGVO)

Right to object to the processing of data for advertising purposes: If your personal data is processed for advertising purposes (direct advertising), you have the right to object at any time to the processing of your personal data for such purposes. An objection means that we may no longer use your personal data for advertising purposes or profiling, but for the other necessary purposes.

If you would like to object to the processing, a simple, informal message to us is sufficient: contact@setyo.de

 

6. Changes to the data protection declaration

We will change our data protection declaration if the offer on our pages or a further development of the options arise or if this becomes necessary due to changed legal regulations. The current version is available on our website.

The exact wording of the legislation can be found here:
https://dsgvo-gesetz.de/