Privacy Policy
- Privacy Pollicy
Privacy policy
www.bio-fluff.com is committed to protecting your privacy.
Our Privacy Policies reflect recent changes in the data protection law and explain how and why we collect
your personal information.
Website Terms of Use
1. Introduction
1.1 These terms and conditions shall govern your use of our website.
1.2 By using our website, you accept these terms and conditions in full; accordingly, if you disagree with
these terms and conditions or any part of these terms and conditions, you must not use our website.
1.3 Our website uses cookies; by using our website or agreeing to these terms and conditions, you consent
to our use of cookies in accordance with the terms of our privacy policy.
2. Credit
2.1 This document was created using a template from SEQ Legal (http://www.seqlegal.com).
3. Content and Intellectual Property Rights
3.1 Title, ownership rights, and intellectual property rights in the content of our website, whether
provided by us or by any other content provider shall remain the sole property of us and / or the other
content provider. We will strongly protect its rights in all countries.
3.2 You may not copy, modify, publish, transmit, transfer or sell, reproduce, create derivative works from,
distribute, perform, display, or in any way exploit any of the content, in whole or in part, except as is
expressly permitted in this agreement.
3.3 You may download or copy the content only for your own personal use, provided that you maintain all
copyright and other notices contained in such content. You may not store electronically any significant
portion of any content.
3.4 All artwork images on our site are copyright protected. The artist retains the copyright for their
artwork at all times. Even when an artwork is sold, the artist retains the copyright for the artwork, unless
expressly stated otherwise by the artist in writing. The use of any artwork image from this site is prohibited
unless prior written permission from the artist is obtained or with the exception as expressly permitted by
Section 4.1(d).
4. Licence to use website
4.1 You may:
(a) view pages from our website in a web browser;
(b) download pages from our website for caching in a web browser;
(c) print pages from our website;
(d) share artwork images on the following social media: Pinterest, Twitter, Facebook, and any social
media which only displays reduced-size images. You must use the share buttons available on our website or
ensure the content credits the artist and links back to our website.
(e) stream video files from our website; and
(f) use our website services by means of a web browser, subject to the other provisions of these terms and
conditions.
4.2 Except as expressly permitted by Section 4.1 or the other provisions of these terms and conditions, you
must not download any material from our website or save any such material to your computer.
4.3 Unless you own or control the relevant rights in the material, you must not exploit material from our
website for a commercial purpose
5. Acceptable use
5.1 You must not:
(a) use our website in any way or take any action that causes, or may cause, damage to the website or
impairment of the performance, availability or accessibility of the website;
(b) use our website in any way that is unlawful, illegal, fraudulent or harmful, or in connection with any
unlawful, illegal, fraudulent or harmful purpose or activity;
(c) use our website to copy, store, host, transmit, send, use, publish or distribute any material which
consists of (or is linked to) any spyware, computer virus, Trojan horse, worm, keystroke logger, rootkit or
other malicious computer software;
(d) conduct any systematic or automated data collection activities (including without limitation scraping,
data mining, data extraction and data harvesting) on or in relation to our website without our express
written consent;
(e) use data collected from our website for any direct marketing activity (including without limitation
email marketing, SMS marketing, telemarketing and direct mailing).
6. Limited warranties
6.1 We do not warrant or represent:
(a) the completeness or accuracy of the information published on our website;
(b) that the material on the website is up to date; or
(c) that the website or any service on the website will remain available.
6.2 We reserve the right to discontinue or alter any or all of our website services, and to stop publishing
our website, at any time in our sole discretion without notice or explanation; and save to the extent
expressly provided otherwise in these terms and conditions, you will not be entitled to any compensation or
other payment upon the discontinuance or alteration of any website services, or if we stop publishing the
website.
6.3 To the maximum extent permitted by applicable law and subject to Section 7.1, we exclude all
representations and warranties relating to the subject matter of these terms and conditions, our website and
the use of our website.
7. Limitations and exclusions of liability
7.1 Nothing in these terms and conditions will:
(a) limit or exclude any liability for death or personal injury resulting from negligence;
(b) limit or exclude any liability for fraud or fraudulent misrepresentation;
(c) limit any liabilities in any way that is not permitted under applicable law; or
(d) exclude any liabilities that may not be excluded under applicable law.
7.2 The limitations and exclusions of liability set out in this Section 7 and elsewhere in these terms and
conditions:
(a) are subject to Section 7.1; and
(b) govern all liabilities arising under these terms and conditions or relating to the subject matter of these
terms and conditions, including liabilities arising in contract, in tort (including negligence) and for breach
of statutory duty.
7.3 We will not be liable to you in respect of any losses arising out of any event or events beyond our
reasonable control.
7.4 We will not be liable to you in respect of any loss or corruption of any data, database or software.
8. Variation
8.1 We may revise these terms and conditions from time to time.
9. Entire agreement
9.1 Subject to Section 7.1, these terms and conditions, together with our privacy and cookies policy, shall
constitute the entire agreement between you and us in relation to your use of our website and shall
supersede all previous agreements between you and us in relation to your use of our website.
10. Law and jurisdiction
10.1 These terms and conditions shall be governed by and construed in accordance with European law.
11. Our details
11.1 This website is owned and operated by Martin Stuebler
12.2 My principal place of business is at Carrer de la Reina Amàlia, 6, 08001 Barcelona, Spain, EU
12.3 you can contact us by writing to the business address given above or use the contact form.
Privacy Notice for Website Visitors
We respect your privacy and are determined to protect your personal data. The purpose of this privacy
notice is to inform you as to how we look after your personal data when you visit our website (regardless of
where you visit it from). We’ll also tell you about your privacy rights and how the data protection law
protects you.
1. Who we are and important information
What is the purpose of this privacy notice?
This privacy notice aims to give you information on how we collect and process your personal data through
your use of this website, including any data you may provide through this website when you make an
enquiry about our service or artist.
Data controller(s)
Martin Stuebler is the controller and responsible for your personal data (collectively referred to as “we” in
this privacy notice).
Third-party links outside of our control
This website includes links to third-party websites, including social media. Clicking on those links or
enabling those connections may allow third parties to collect or share data about you. We do not control
these third-party websites and are not responsible for their privacy policies.
When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. The personal data we collect about you
Personal data, or personal information, means any information about an individual from which that person
can be identified.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped
together as follows:
- Identity Data includes your name.
- Contact Data includes your email.
- We also collect, use and share Aggregated Data, such as statistical or demographic data for any purpose.
Aggregated Data may be derived from your personal data but is not considered personal data in law as
this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage
data to calculate the percentage of users viewing a specific product on our website. However, if we
combine or connect Aggregated Data with your personal data so that it can directly or indirectly
identify you, we treat the combined data as personal data which will be used in accordance with this
privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race
or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union
membership, information about your health and genetic and biometric data). Nor do we collect any
information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect your personal data under the terms of a contract we have with you and you fail to
provide that data when requested, we may not be able to perform the contract we have or are trying to enter
into with you (for example, signing up to our membership). The policy you are reading is for website
visitors but if you are an existing artist member or thinking about subscribing to our membership, please
read our customer privacy notice
3. How we collect your personal data
We have put in place procedures to deal with any suspected personal data breach and will notify you and
any applicable regulator of a breach where we are legally required to do so.
8. Data retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for,
including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and
sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your
personal data, the purposes for which we process your personal data and whether we can achieve those
purposes through other means, and the applicable legal requirements.
In some circumstances you can ask us to delete your data: see your legal rights below for further
information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with
you) for research or statistical purposes in which case we may use this information indefinitely without
further notice to you.
9. Your legal rights
Unless subject to an exemption under the data protection laws, you have the following rights with respect
to your personal data:
- The right to request a copy of the personal data which we hold about you;
- The right to request that we correct any personal data if it is found to be inaccurate or out of date;
- The right to request your personal data is erased where it is no longer necessary to retain such data;
- The right to withdraw your consent to the processing at any time, where consent was the lawful basis
for processing your data; - The right to request that we provide you with your personal data and where possible, to transmit that
data directly to another data controller, (known as the right to data portability), where applicable i.e.
where our processing is based on consent or is necessary for the performance of our contract with you
or where we process your data by automated means); - The right, where there is a dispute in relation to the accuracy or processing of your personal data, to
request a restriction is placed on further processing; - The right to object to our processing of personal data, where applicable i.e. where processing is based
on our legitimate interests (or in performance of a task in the public interest/exercise of official
authority); direct marketing or processing for the purposes of scientific/historical research and
statistics).
If you wish to exercise any of the rights set out above, please contact us. No fee required – with some
exceptions
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However,
we may charge a reasonable admin fee if your request is clearly unfounded, repetitive or excessive.
Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your
right to access your personal data (or to exercise any of your other rights). This is a security measure to
ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact
you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a
month if your request is particularly complex or you have made a number of requests. In this case, we will
notify you and keep you updated.
10. Queries, requests or concerns
To exercise all relevant rights, queries or complaints in relation to this policy or any other data protection
matter between you and us, please contact us using the contact form on this website.
Privacy Notice for Customers
Introduction
Martin Stuebler (“We”) are committed to protecting and respecting your privacy.
This policy (together with our Website Visitors Privacy Notice for our website visitors) sets out the basis on
which any personal data we collect from you, or that you provide to us, will be processed by us. Please read
the following carefully to understand our views and practices regarding your personal data and how we will
treat it.
The rules on processing of personal data are set out in the General Data Protection Regulation (the
“GDPR”).
1. Definitions
Data controller – A controller determines the purposes and means of processing personal data.
Data processor – A processor is responsible for processing personal data on behalf of a controller.
Data subject – Natural person
Categories of data: Personal data and special categories of personal data
Personal data – The GDPR applies to ‘personal data’ meaning any information relating to an identifiable
person who can be directly or indirectly identified in particular by reference to an identifier (as explained in
Article 6 of GDPR). For example name, home address or private email address. Online identifiers include IP
addresses and cookies.
Special categories personal data – The GDPR refers to sensitive personal data as ‘special categories of
personal data’ (as explained in Article 9 of GDPR). The special categories specifically include genetic data,
and biometric data where processed to uniquely identify an individual. Other examples include racial and
ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or
philosophical beliefs.
Processing – means any operation or set of operations which is performed on personal data or on sets of
personal data, whether or not by automated means, such as collection, recording, organisation, structuring,
storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or
otherwise making available, alignment or combination, restriction, erasure or destruction.
Third party – means a natural or legal person, public authority, agency or body other than the data subject,
controller, processor and persons who, under the direct authority of the controller or processor, are
authorised to process personal data.
2. Who are we?
Martin Stuebler is the data controller. This means we decide how your personal data is processed and for
what purposes. Our contact details can be found at the bottom of this page.
3. The purpose(s) of processing your personal data
We use your personal data for the following purposes:
To maintain our own accounts and records;
To contact you about your account with us;
To inform you of news, services and general information pertaining to our own company, that we feel you
may be interested in.
4. The categories of personal data concerned
With reference to the categories of personal data described in the definitions section, we may process the
following categories of your data:
- Name
- Address
- E-mail address
- Website tracking data (please see our Website Visitors Privacy Notice.
5. What is our legal basis for processing your personal data:
a. CONTRACT is our lawful basis for processing personal data in the form of contact information and
financial information for the purposes of processing any orders placed with us, managing customer
accounts and informing the customer about anything necessary for our ability to perform the contract. It is
also our lawful basis for displaying your username, which may be your real name and therefore constitute
personal data, publicly on our website and on our social media channels.
b. CONSENT is our lawful basis for processing the personal data of existing customers for the purpose of
sending marketing communications. We only send email marketing communications that provide
information and offers relating to our own business and website. The data subject can opt out at any time.
c. LEGITIMATE INTEREST is our lawful basis for processing the personal data of artists, for the purpose
of sending email communications about our website in relation to the sale of the artists’ work, where it is
clear that the artist’s personal data was intended by the artist to be processed in relation to the sale of their
work. The artist’s personal data that we may process will include a contact name, email address and phone
number. The email communication will only ever be in relation to the sale of the artist’s work and the
service we offer in relation to the sale of the artists work. The artist can opt out of further communications
at any time.
6. Disclosing your personal data
- Your personal data will be treated as strictly confidential. Strict control will always be maintained
regarding any access to your personal data by service providers carrying out diagnostics or repairs on
our website and IT systems. - Your username, which may be your personal name and therefore constitute personal data, will be
displayed on our website to the public and shared on social media by us and website visitors, subject to
the terms of your membership with us.
7. How long do we keep your personal data?
We retain Personal Data for as long as necessary to fulfill the purposes for which it was collected as outlined
in section 3 above, unless a longer retention period is required by law. When your Personal Data is no
longer required for the purpose it was collected or as required by applicable law, it will be deleted and/or
returned to you in accordance with applicable law.
Personal data collected for the sole purpose of sending email communications to an artist that is not a
customer, in accordance to 5.C. above, may be retained for several years once this privacy policy has been
issued (within a month after the data has been copied from the original source) and will be deleted when no
longer required or if requested by the data subject/artist.
8. Providing us with your personal data
As a customer, your personal data is likely to be required for us to carry out the tasks relevant to the contract
between us. Without it we will not be able to process your membership, contact you about any issues
relating to your membership and you would not be able to complete registration on the website.
9. Your rights and your personal data
Unless subject to an exemption under the GDPR, you have the following rights with respect to your
personal data:
- The right to request a copy of the personal data which we hold about you;
- The right to request that we correct any personal data if it is found to be inaccurate or out of date;
- The right to request your personal data is erased where it is no longer necessary to retain such data;
- The right to withdraw your consent to the processing at any time, where consent was the lawful basis
for our processing the data. - The right to request that we provide you with your personal data and where possible, to transmit that
data directly to another data controller, (known as the right to data portability), (where applicable i.e.
where the processing is based on consent or is necessary for the performance of a contract with the data
subject and where the data controller processes the data by automated means); - The right, where there is a dispute in relation to the accuracy or processing of your personal data, to
request a restriction is placed on further processing; - The right to object to the processing of personal data, (where applicable i.e. direct marketing or where
processing is based on legitimate interest)
10. Third party processing of financial data
Your card payment data required for membership subscription is processed by Paypal, which is a third party
secure payment platform. We do not store or have access to your financial and card payment data. For
details about how your card payment data is processed please read the PayPal privacy policy We are a
biomaterials startup, focusing solely on reimaging fluffy materials. We have created the world's first
completely plant-based alternative to fur, shearling, and plush.
We are based in Paris and NY and produce our materials in Europe
11. Transfer of Data Abroad
We do not transfer personal data outside the EEA
12. Automated Decision Making
We do not use any form of automated decision making in our business
13. Further processing
If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we
will provide you with a new notice explaining this new use prior to commencing the processing and setting
out the relevant purposes and processing conditions.
14. Changes to our privacy policy
Any changes we may make to our privacy policy in the future will be notified to you by e-mail.
15. How to make a complaint
To exercise all relevant rights, queries or complaints please use the contact form.
Information about our use of cookies
Our website uses cookies to distinguish you from other users of our website. This helps us to provide you
with a good experience when you browse our website and also allows us to improve our site. By continuing
to browse the site, you are agreeing to our use of cookies.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your
computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
We use the following cookies:
- Strictly necessary cookies. These are cookies that are required for the operation of our website. They
include, for example, cookies that enable you to log into secure areas of our website. - Analytical/performance cookies. They allow us to recognise and count the number of visitors and to
see how visitors move around our website when they are using it. This helps us to improve the way our
website works, for example, by ensuring that users are finding what they are looking for easily. - Functionality cookies. These are used to recognise you when you return to our website. This enables us
to personalise our content for you, greet you by name and remember your preferences (for example,
your choice of language or region).
Please note that third parties (including, for example, providers of external services like web traffic analysis
services) may also use cookies, over which we have no control. These cookies are likely to be
analytical/performance cookies or targeting cookies.
You block cookies by activating the setting on your browser that allows you to refuse the setting of all or
some cookies.
Back to home page
Through this website we use the following method to collect data from and about you:
- Directly. You may give us your identity and contact data when contacting us by email or when
subscribing to membership on our website.
- Indirectly. When you email an artist on the site via the contact form on either the artist’s profile page or
any of their artwork showcase pages, a copy of that message is kept for a while on our own email
system. We do not monitor these emails unless the artist reports an issue with the content of the email
or reports an issue they may have had with receiving messages via the website. Any replies you make
directly to an email the artist sends you will not be seen or stored by us. We also do not see any or store
any email the artist send you.
4. How we use your personal data
We will only use your personal data when the law allows us to.
Answering email enquiries
In order to do this we have to process the following types of data: Identity data (your name) and Contact
data (your email address). Our lawful basis is for the performance of a contract with you, which simply
meant that by sending an email you expect that your data has to be processed in order for us to respond to
your enquiry.
Marketing
We do not collect personal data through this website for the purpose of marketing.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access
cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible
or not function properly. For more information about the cookies we use, please view our cooky policy
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably
consider that we need to use it for another reason and that reason is compatible with the original purpose.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the
legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with
the above rules, where this is required or permitted by law.
5. Who we share your personal data with
We may have to share your personal data with the parties set out below for the purposes set out in the table
in paragraph 4 above.
- Providers based in the EU who provide IT and System administration services and website
management services.
We require all third parties to respect the security of your personal data and to treat it in accordance with
the law. We do not allow our third-party service providers to use your personal data for their own purposes
and only permit them to process your personal data for specified purposes and in accordance with our
instructions.
6. International transfers
We do not transfer your personal data outside the European Economic Area (EEA)
7. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally
lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your
personal data to third parties who have a business need to know. They will only process your personal data
on our instructions, and they are subject to a duty of confidentiality.
We will only use your personal data when the law allows us to.
Answering email enquiries
In order to do this we have to process the following types of data: Identity data (your name) and Contact
data (your email address). Our lawful basis is for the performance of a contract with you, which simply
meant that by sending an email you expect that your data has to be processed in order for us to respond to
your enquiry.
Marketing
We do not collect personal data through this website for the purpose of marketing.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access
cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible
or not function properly. For more information about the cookies we use, please view our cooky policy
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably
consider that we need to use it for another reason and that reason is compatible with the original purpose.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the
legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with
the above rules, where this is required or permitted by law.
5. Who we share your personal data with
We may have to share your personal data with the parties set out below for the purposes set out in the table
in paragraph 4 above.
Providers based in the EU who provide IT and System administration services and website management
services.
We require all third parties to respect the security of your personal data and to treat it in accordance with
the law. We do not allow our third-party service providers to use your personal data for their own purposes
and only permit them to process your personal data for specified purposes and in accordance with our
instructions
6. International transfers
We do not transfer your personal data outside the European Economic Area (EEA)
7. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally
lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your
personal data to third parties who have a business need to know. They will only process your personal data
on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and
any applicable regulator of a breach where we are legally required to do so.
8. Data retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for,
including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and
sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your
personal data, the purposes for which we process your personal data and whether we can achieve those
purposes through other means, and the applicable legal requirements.
In some circumstances you can ask us to delete your data: see your legal rights below for further
information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with
you) for research or statistical purposes in which case we may use this information indefinitely without
further notice to you.
9. Your legal rights
Unless subject to an exemption under the data protection laws, you have the following rights with respect
to your personal data:
The right to request a copy of the personal data which we hold about you;
The right to request that we correct any personal data if it is found to be inaccurate or out of date;
The right to request your personal data is erased where it is no longer necessary to retain such data;
The right to withdraw your consent to the processing at any time, where consent was the lawful basis for
processing your data;
The right to request that we provide you with your personal data and where possible, to transmit that data
directly to another data controller, (known as the right to data portability), where applicable i.e. where our
processing is based on consent or is necessary for the performance of our contract with you or where we
process your data by automated means);
The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request
a restriction is placed on further processing;
The right to object to our processing of personal data, where applicable i.e. where processing is based on our
legitimate interests (or in performance of a task in the public interest/exercise of official authority); direct
marketing or processing for the purposes of scientific/historical research and statistics).
If you wish to exercise any of the rights set out above, please contact us. No fee required – with some
exceptions
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However,
we may charge a reasonable admin fee if your request is clearly unfounded, repetitive or excessive.
Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your
right to access your personal data (or to exercise any of your other rights). This is a security measure to
ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact
you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a
month if your request is particularly complex or you have made a number of requests. In this case, we will
notify you and keep you updated.
10. Queries, requests or concerns
To exercise all relevant rights, queries or complaints in relation to this policy or any other data protection
matter between you and us, please contact us using the contact form on this website.
Privacy Notice for Customers
Introduction
Martin Stuebler (“We”) are committed to protecting and respecting your privacy.
This policy (together with our Website Visitors Privacy Notice for our website visitors) sets out the basis on
which any personal data we collect from you, or that you provide to us, will be processed by us. Please read
the following carefully to understand our views and practices regarding your personal data and how we will
treat it.
The rules on processing of personal data are set out in the General Data Protection Regulation (the
“GDPR”).
1. Definitions
Data controller – A controller determines the purposes and means of processing personal data.
Data processor – A processor is responsible for processing personal data on behalf of a controller.
Data subject – Natural person
Categories of data: Personal data and special categories of personal data
Personal data – The GDPR applies to ‘personal data’ meaning any information relating to an identifiable
person who can be directly or indirectly identified in particular by reference to an identifier (as explained in
Article 6 of GDPR). For example name, home address or private email address. Online identifiers include IP
addresses and cookies.
Special categories personal data – The GDPR refers to sensitive personal data as ‘special categories of
personal data’ (as explained in Article 9 of GDPR). The special categories specifically include genetic data,
and biometric data where processed to uniquely identify an individual. Other examples include racial and
ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or
philosophical beliefs.
Processing – means any operation or set of operations which is performed on personal data or on sets of
personal data, whether or not by automated means, such as collection, recording, organisation, structuring,
storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or
otherwise making available, alignment or combination, restriction, erasure or destruction.
Third party – means a natural or legal person, public authority, agency or body other than the data subject,
controller, processor and persons who, under the direct authority of the controller or processor, are
authorised to process personal data.
2. Who are we?
Martin Stuebler is the data controller. This means we decide how your personal data is processed and for
what purposes. Our contact details can be found at the bottom of this page.
3. The purpose(s) of processing your personal data
We use your personal data for the following purposes:
To maintain our own accounts and records;
To contact you about your account with us;
To inform you of news, services and general information pertaining to our own company, that we feel you
may be interested in.
4. The categories of personal data concerned
With reference to the categories of personal data described in the definitions section, we may process the
following categories of your data:
Name
Address
E-mail address
Website tracking data (please see our Website Visitors Privacy Notice.
5. What is our legal basis for processing your personal data:
a. CONTRACT is our lawful basis for processing personal data in the form of contact information and
financial information for the purposes of processing any orders placed with us, managing customer
accounts and informing the customer about anything necessary for our ability to perform the contract. It is
also our lawful basis for displaying your username, which may be your real name and therefore constitute
personal data, publicly on our website and on our social media channels.
b. CONSENT is our lawful basis for processing the personal data of existing customers for the purpose of
sending marketing communications. We only send email marketing communications that provide
information and offers relating to our own business and website. The data subject can opt out at any time.
c. LEGITIMATE INTEREST is our lawful basis for processing the personal data of artists, for the purpose
of sending email communications about our website in relation to the sale of the artists’ work, where it is
clear that the artist’s personal data was intended by the artist to be processed in relation to the sale of their
work. The artist’s personal data that we may process will include a contact name, email address and phone
number. The email communication will only ever be in relation to the sale of the artist’s work and the
service we offer in relation to the sale of the artists work. The artist can opt out of further communications
at any time.
6. Disclosing your personal data
Your personal data will be treated as strictly confidential. Strict control will always be maintained regarding
any access to your personal data by service providers carrying out diagnostics or repairs on our website and
IT systems.
Your username, which may be your personal name and therefore constitute personal data, will be displayed
on our website to the public and shared on social media by us and website visitors, subject to the terms of
your membership with us.
7. How long do we keep your personal data?
We retain Personal Data for as long as necessary to fulfill the purposes for which it was collected as outlined
in section 3 above, unless a longer retention period is required by law. When your Personal Data is no
longer required for the purpose it was collected or as required by applicable law, it will be deleted and/or
returned to you in accordance with applicable law.
Personal data collected for the sole purpose of sending email communications to an artist that is not a
customer, in accordance to 5.C. above, may be retained for several years once this privacy policy has been
issued (within a month after the data has been copied from the original source) and will be deleted when no
longer required or if requested by the data subject/artist.
8. Providing us with your personal data
As a customer, your personal data is likely to be required for us to carry out the tasks relevant to the contract
between us. Without it we will not be able to process your membership, contact you about any issues
relating to your membership and you would not be able to complete registration on the website.
9. Your rights and your personal data
Unless subject to an exemption under the GDPR, you have the following rights with respect to your
personal data:
The right to request a copy of the personal data which we hold about you;
The right to request that we correct any personal data if it is found to be inaccurate or out of date;
The right to request your personal data is erased where it is no longer necessary to retain such data;
The right to withdraw your consent to the processing at any time, where consent was the lawful basis for
our processing the data.
The right to request that we provide you with your personal data and where possible, to transmit that data
directly to another data controller, (known as the right to data portability), (where applicable i.e. where the
processing is based on consent or is necessary for the performance of a contract with the data subject and
where the data controller processes the data by automated means);
The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request
a restriction is placed on further processing;
The right to object to the processing of personal data, (where applicable i.e. direct marketing or where
processing is based on legitimate interest)
10. Third party processing of financial data
Your card payment data required for membership subscription is processed by Paypal, which is a third party
secure payment platform. We do not store or have access to your financial and card payment data. For
details about how your card payment data is processed please read the PayPal privacy policy
https://www.paypal.com/va/webapps/mpp/ua/privacy-full
11. Transfer of Data Abroad
We do not transfer personal data outside the EEA
12. Automated Decision Making
We do not use any form of automated decision making in our business
13. Further processing
If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we
will provide you with a new notice explaining this new use prior to commencing the processing and setting
out the relevant purposes and processing conditions.
14. Changes to our privacy policy
Any changes we may make to our privacy policy in the future will be notified to you by e-mail.
15. How to make a complaint
To exercise all relevant rights, queries or complaints please use the contact form.
Information about our use of cookies
Our website uses cookies to distinguish you from other users of our website. This helps us to provide you
with a good experience when you browse our website and also allows us to improve our site. By continuing
to browse the site, you are agreeing to our use of cookies.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your
computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
We use the following cookies:
Strictly necessary cookies. These are cookies that are required for the operation of our website. They
include, for example, cookies that enable you to log into secure areas of our website.
Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see
how visitors move around our website when they are using it. This helps us to improve the way our website
works, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies. These are used to recognise you when you return to our website. This enables us to
personalise our content for you, greet you by name and remember your preferences (for example, your
choice of language or region).
Please note that third parties (including, for example, providers of external services like web traffic analysis
services) may also use cookies, over which we have no control. These cookies are likely to be
analytical/performance cookies or targeting cookies.
You block cookies by activating the setting on your browser that allows you to refuse the setting of all or
some cookies.
10. Queries, requests or concerns
To exercise all relevant rights, queries or complaints in relation to this policy or any other data protection matter between
you and us, please contact us using the contact form on this website.
Privacy Notice for Customers
Introduction
Martin Stuebler (“We”) are committed to protecting and respecting your privacy.
This policy (together with our Website Visitors Privacy Notice for our website visitors) sets out the basis on which any
personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully
to understand our views and practices regarding your personal data and how we will treat it.
The rules on processing of personal data are set out in the General Data Protection Regulation (the “GDPR”).
1. Definitions
Data controller – A controller determines the purposes and means of processing personal data.
Data processor – A processor is responsible for processing personal data on behalf of a controller.
Data subject – Natural person
Categories of data: Personal data and special categories of personal data
Personal data – The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who
can be directly or indirectly identified in particular by reference to an identifier (as explained in Article 6 of GDPR). For
example name, home address or private email address. Online identifiers include IP addresses and cookies.
Special categories personal data – The GDPR refers to sensitive personal data as ‘special categories of personal data’ (as
explained in Article 9 of GDPR). The special categories specifically include genetic data, and biometric data where
processed to uniquely identify an individual. Other examples include racial and ethnic origin, sexual orientation, health
data, trade union membership, political opinions, religious or philosophical beliefs.
Processing – means any operation or set of operations which is performed on personal data or on sets of personal data,
whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or
alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available,
alignment or combination, restriction, erasure or destruction.
Third party – means a natural or legal person, public authority, agency or body other than the data subject, controller,
processor and persons who, under the direct authority of the controller or processor, are authorised to process personal
data.
2. Who are we?
Martin Stuebler is the data controller. This means we decide how your personal data is processed and for what purposes.
Our contact details can be found at the bottom of this page.
3. The purpose(s) of processing your personal data
We use your personal data for the following purposes:
To maintain our own accounts and records;
To contact you about your account with us;
To inform you of news, services and general information pertaining to our own company, that we feel you may be
interested in.
4. The categories of personal data concerned
With reference to the categories of personal data described in the definitions section, we may process the following
categories of your data:
Name
Address
E-mail address
Website tracking data (please see our Website Visitors Privacy Notice.
5. What is our legal basis for processing your personal data:
a. CONTRACT is our lawful basis for processing personal data in the form of contact information and financial
information for the purposes of processing any orders placed with us, managing customer accounts and informing the
customer about anything necessary for our ability to perform the contract. It is also our lawful basis for displaying your
username, which may be your real name and therefore constitute personal data, publicly on our website and on our
social media channels.
b. CONSENT is our lawful basis for processing the personal data of existing customers for the purpose of sending
marketing communications. We only send email marketing communications that provide information and offers
relating to our own business and website. The data subject can opt out at any time.
c. LEGITIMATE INTEREST is our lawful basis for processing the personal data of artists, for the purpose of sending
email communications about our website in relation to the sale of the artists’ work, where it is clear that the artist’s
personal data was intended by the artist to be processed in relation to the sale of their work. The artist’s personal data
that we may process will include a contact name, email address and phone number. The email communication will only
ever be in relation to the sale of the artist’s work and the service we offer in relation to the sale of the artists work. The
artist can opt out of further communications at any time.
6. Disclosing your personal data
Your personal data will be treated as strictly confidential. Strict control will always be maintained regarding any access to
your personal data by service providers carrying out diagnostics or repairs on our website and IT systems.
Your username, which may be your personal name and therefore constitute personal data, will be displayed on our
website to the public and shared on social media by us and website visitors, subject to the terms of your membership
with us.
7. How long do we keep your personal data?
We retain Personal Data for as long as necessary to fulfill the purposes for which it was collected as outlined in section 3
above, unless a longer retention period is required by law. When your Personal Data is no longer required for the
purpose it was collected or as required by applicable law, it will be deleted and/or returned to you in accordance with
applicable law.
Personal data collected for the sole purpose of sending email communications to an artist that is not a customer, in
accordance to 5.C. above, may be retained for several years once this privacy policy has been issued (within a month after
the data has been copied from the original source) and will be deleted when no longer required or if requested by the data
subject/artist.
8. Providing us with your personal data
As a customer, your personal data is likely to be required for us to carry out the tasks relevant to the contract between us.
Without it we will not be able to process your membership, contact you about any issues relating to your membership
and you would not be able to complete registration on the website.
9. Your rights and your personal data
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:
The right to request a copy of the personal data which we hold about you;
The right to request that we correct any personal data if it is found to be inaccurate or out of date;
The right to request your personal data is erased where it is no longer necessary to retain such data;
The right to withdraw your consent to the processing at any time, where consent was the lawful basis for our processing
the data.
The right to request that we provide you with your personal data and where possible, to transmit that data directly to
another data controller, (known as the right to data portability), (where applicable i.e. where the processing is based on
consent or is necessary for the performance of a contract with the data subject and where the data controller processes
the data by automated means);
The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction
is placed on further processing;
The right to object to the processing of personal data, (where applicable i.e. direct marketing or where processing is based
on legitimate interest)
10. Third party processing of financial data
Your card payment data required for membership subscription is processed by Paypal, which is a third party secure
payment platform. We do not store or have access to your financial and card payment data. For details about how your
card payment data is processed please read the PayPal privacy policy
https://www.paypal.com/va/webapps/mpp/ua/privacy-full
11. Transfer of Data Abroad
We do not transfer personal data outside the EEA
12. Automated Decision Making
We do not use any form of automated decision making in our business
13. Further processing
If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide
you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes
and processing conditions.
14. Changes to our privacy policy
Any changes we may make to our privacy policy in the future will be notified to you by e-mail.
15. How to make a complaint
To exercise all relevant rights, queries or complaints please use the contact form.
Information about our use of cookies
Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good
experience when you browse our website and also allows us to improve our site. By continuing to browse the site, you are
agreeing to our use of cookies.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you
agree. Cookies contain information that is transferred to your computer’s hard drive.
We use the following cookies:
Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for
example, cookies that enable you to log into secure areas of our website.
Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors
move around our website when they are using it. This helps us to improve the way our website works, for example, by
ensuring that users are finding what they are looking for easily.
Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise
our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
Please note that third parties (including, for example, providers of external services like web traffic analysis services) may
also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or
targeting cookies.
You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies.
12. Automated Decision Making
We do not use any form of automated decision making in our business
13. Further processing
If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we
will provide you with a new notice explaining this new use prior to commencing the processing and setting
out the relevant purposes and processing conditions.
14. Changes to our privacy policy
Any changes we may make to our privacy policy in the future will be notified to you by e-mail.
15. How to make a complaint
To exercise all relevant rights, queries or complaints please use the contact form.
Information about our use of cookies
Our website uses cookies to distinguish you from other users of our website. This helps us to provide you
with a good experience when you browse our website and also allows us to improve our site. By continuing
to browse the site, you are agreeing to our use of cookies.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your
computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
We use the following cookies:
Strictly necessary cookies. These are cookies that are required for the operation of our website. They
include, for example, cookies that enable you to log into secure areas of our website.
Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see
how visitors move around our website when they are using it. This helps us to improve the way our website
works, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies. These are used to recognise you when you return to our website. This enables us to
personalise our content for you, greet you by name and remember your preferences (for example, your
choice of language or region).
Please note that third parties (including, for example, providers of external services like web traffic analysis
services) may also use cookies, over which we have no control. These cookies are likely to be
analytical/performance cookies or targeting cookies.
You block cookies by activating the setting on your browser that allows you to refuse the setting of all or
some cookies.