Shopeybd respects the data subject’s privacy and works hard to safeguard the privacy of the data subject’s data. We realize that the exciting growth of the Internet and online services raise questions concerning the nature, use, and confidentiality of information collected about consumers. We want the data subject to know that we apply our long-standing commitment to safeguarding privacy to our online and Internet activities.

By providing Personal Information to us, the data subject is consenting to this Privacy Statement and the collection, use, access, transfer, storage, and processing of the data subject’s personal information as described in this Privacy Statement.

The use of the Internet pages of Shopeybd is possible without any indication of personal data; however, if a data subject wants to use our services on the Portals, including, without limitation, reselling and retailing online games and related merchandises or games publishing, processing of personal data could become necessary. If the processing of personal data is necessary and there is no statutory basis for such processing, we will obtain the data subject’s consent.

The processing of personal data, such as the name, address, e-mail address, or telephone number of a data subject shall always be in line with the General Data Protection Regulation (GDPR), and under the country-specific data protection regulations applicable to Shopeybd. Using this data protection declaration, our enterprise would like to inform the general public of the nature, scope, and purpose of the personal data we collect, use, and process. Furthermore, data subjects are informed, using this data protection declaration, of the rights to which they are entitled.

As the controller, Shopeybd has implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through the Portals. However, Internet-based data transmissions may in principle have security gaps, so absolute protection may not be guaranteed. For this reason, every data subject is free to transfer personal data to us via alternative means, e.g. by telephone.

In addition to GDPR, please note that we collect, store and handle the personal information of individuals under the Personal Data Protection Act 2010 (“PDPA”) and the laws of Bangladesh.

Please read the Privacy Statement below to understand how we use the personal information we may collect from the data subject. We will not use or share the data subject’s information with anyone except as described in this Privacy Policy.

The data protection declaration of Shopeybd is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our data protection declaration should be legible and understandable for the general public, as well as our customers and partners. To ensure this, we would like to begin by explaining the terminology used.

In this data protection declaration, we use, inter alia, the following terms:

Personal data
Personal data means any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Data subject
The data subject is any identified or identifiable natural person, whose personal data is processed by Shopeybd.

Processing
Processing is any operation or set of operations that are performed on personal data or sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Restriction of processing
Restriction of processing is the marking of stored personal data to limit their processing in the future.

Profiling
Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular, to analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.

Pseudonymization
Pseudonymisation is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

Controller or controller responsible for the processing
The controller or controller responsible for the processing is the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

Processor
A processor is a natural or legal person, public authority, agency, or other body which processes personal data on behalf of Shopeybd.

Recipient
The recipient is a natural or legal person, public authority, agency, or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry under Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall comply with the applicable data protection rules according to the purposes of the processing.

Third-party
Third-party is 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 Shopeybd or processor, are authorized to process personal data.

Consent
Consent of the data subject is any freely given, specific, informed, and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

Other capitalized terms not defined above, shall have the meaning granted to them in our Terms of Services.

Controller for the General Data Protection Regulation (GDPR), other data protection laws applicable in Member states of the European Union, and other provisions related to data protection this is:

SHOPEYBD
Abeda Noor Foundation, Choto Bari, Gollai, Chandina, Cumilla-3510
Phone: +8809638882999
Email: support@shopeybd.com
Website: https://shopeybd.com

We value each data subject’s trust in providing us with their personal information.

A customer’s name, address (postal and e-mail) and telephone number are the most important pieces of information, but we might request other information, based on, for example, the Service(s) being ordered or promoted.

SHARING, DISCLOSURE, AND SALE OF PERSONAL DATA
Shopeybd does not share, disclose or sell any personally identifiable information (such as the data subject’s name, address, telephone number, or e-mail address) collected online on Shopeybd’s Portals with other unaffiliated companies or organizations for non-Shopeybd marketing purposes. Because this information is a critical part of our business, it would be treated like our other assets in the context of a merger, sale, or other corporate reorganization or legal proceeding.

We will only provide personally identifiable online information in response to subpoenas and other legal demands, and where we believe that disclosing this information is necessary to identify, contact or bring legal action against individuals who may be endangering public safety or interfering with Shopeybd’ services, or with our customers’ or others’ use of them.

DISCLOSURE OF THE DATA SUBJECT’S INFORMATION (IF NEEDED)
When the data subject has provided personal information to us for a particular purpose, we may disclose the data subject’s information to other companies that we have engaged to assist us in fulfilling the data subject’s request. This may include but is not limited to, fulfillment houses, billing services, transaction managers, credit verification services, and other third-party service providers. We may also disclose any of the data subject’s personal information to law enforcement or other appropriate third parties in connection with criminal investigations, investigation of fraud, infringement of intellectual property rights, or other suspected illegal activities, or as otherwise may be required by applicable law, or, as we deem necessary in our sole discretion, to protect the legitimate legal interests of Shopeybd.

INFORMATION ON CHILDREN AND UNDERAGE ADOLESCENTS
Children and underage adolescents may be users of our products and services, provided that they are duly authorized by their parents or guardians or that their parents or guardians act on their behalf. If their parents or guardians of these children become aware of unauthorized data processing, they may submit their inquiries or complaints to support@shopeybd.com.

WHEN DO WE COLLECT THE DATA SUBJECT’S PERSONAL INFORMATION?
We may collect personal information directly from data subjects when they:-

• communicate with us (for example when the data subjects submit an application form to become our customer, or when they contact us for any inquiries including by calling our customer service, registering for an Account, using our Portals’ Services, or receiving our publications (for example, newsletters);
• participate in any of our surveys;
• enter into or participate in any competitions, contests, or loyalty programs run/organized by Shopeybd;
• register interest and/or request information (through our online portals or other available channels) or subscribe to our products and/or Services;
• respond to any marketing materials we send out;
• visit or browse our Portals;
• complain about us; and/or
• provide feedback to us (for example via our Portals or in hard copy).

Other than personal information obtained from the data subject directly (as detailed above), we may also obtain the data subject’s personal information from third parties we deal with or are connected with the data subject (credit reference agencies or financial institutions), and from such other sources where the data subject has given their consent for the disclosure of information relating to the data subject, and/or where otherwise lawfully permitted.

HOW DO WE COLLECT THE DATA SUBJECT’S PERSONAL INFORMATION?
Shopeybd collects information online by asking the data subject for it, for example, when the data subject orders a Service, applies for a job or responds to a survey, offer, or other promotion.

Cookies: Shopeybd may also use “cookies” and similar technology to obtain information about the data subject’s visits to our Portals or the data subject’s responses to e-mail from us – both individually and in aggregated data that does not identify the data subject. These reporting tools tell us the parts of our Portals or e-mails in which the data subject showed an interest or took some action, and help us improve the quality and usefulness of our Portals.

Content: Data subjects also provide us information in the content they post to the Portals. The data subject’s content (such as reviews, photos, and videos) and metadata about the data subject’s content will be viewed by other users. Shopeybd can but has no obligation, to monitor the content data subjects post on the Portals. We can remove any information data subjects post for any reason or no reason.

Payment Method: Data subjects will also be asked to submit Personal Information depending on the payment method data subjects choose when accessing, purchasing, or subscribing to one of our products or Services. For example, if the data subject chooses to pay for a product/service by credit card, the data subject will be required to provide us the name of the data subject’s credit card issuer, credit card number, billing address, CVV number, and expiration date.

Log Files: When data subjects use the Portals, our servers automatically record certain information sent by the data subject’s web browser. These server logs may include information such as the data subject’s web request, Internet Protocol (“IP”) address, browser type, referring / exit pages and URLs, the number of clicks, and how the data subject interacts with links on the Portals, domain names, landing pages, pages viewed, mobile carrier, and other such information.

Geo-Location Information: When data subjects use the Portals by or through a mobile device, we may access, collect, monitor, and/or remotely store “location data,” which may include GPS coordinates (e.g. latitude and/or longitude) or similar information regarding the location of the data subject’s mobile device.

Third-Party Tools: Shopeybd uses third-party analytics tools, to help understand the use of the Portals. Many of these tools collect the information sent by the data subject’s browser as part of a web page request, including cookies and the data subject’s IP address. These analytics tools also receive this information and their use of it is governed by their privacy policy.

HOW DO WE USE THE DATA SUBJECT’S INFORMATION
Shopeybd uses the personally identifiable information collected online principally to provide data subjects with the service(s) data subjects have ordered and to let data subjects know about other offerings which may be of interest to data subjects. Postal and e-mail address information, for example, enables communication about services offered and ordered, as well as the proper provisioning and billing of those services. At any point in time, should the data subject feel the need to opt out of future communications with Shopeybd, options are given within the data subject’s Account to exclude those communicated messages to the data subject.

WHAT WE REQUEST FROM DATA SUBJECTS
We request for data subjects to provide us with accurate and complete information about themselves and any other person whose personal information the data subject provides us. We further request that data subjects update the information that they have provided us when it becomes incorrect or out of date by contacting us. This obligation is a condition to the provision of our Services to data subjects and/or any other person authorized or permitted by the data subject or the data subject’s organization/company to use the products and/or Services.

WE PROMISE PRIVACY & SECURITY
Both of us together play an important role in protecting against online fraud. The data subject should be careful that any information including their User ID, Password, or Security Code is not compromised by ensuring that each data subject does not knowingly or accidentally share, provide or facilitate unauthorized use of it. Do not share;

• User ID – each data subject and every account user will receive a unique identifier.
• Password – is the passphrase that each data subject uses to access our Services.
• Security Code – sent to each data subject to verify the data subject’s access to our Services.

At Shopeybd, we use encryption, firewalls, and other technology and security procedures to help protect the accuracy and security of the data subject’s personal information and prevent unauthorized access or improper use. For example, data subjects will note that while using some features of the Shopeybd’s Portal, data subjects will need to submit a password or some other type of authenticating information.

NOTICES TO THE CHANGES IN PRIVACY POLICIES
Shopeybd reserves the right to change this Privacy Policy at any time by notifying registered users via e-mail of the existence of a new Privacy Policy and/or posting the new Privacy Policy on Shopeybd Portals. All changes to the Privacy Policy will be effective when posted, and the data subject’s continued use of Shopeybd, product, or service after the posting will constitute the data subject’s acceptance of, and agreement to be bound by, those changes.

We use a tracking pixel. A tracking pixel is a miniature graphic embedded in a web page to enable log file recording and log file analysis to subsequently perform statistical analysis. Shopeybd also sets a cookie on the information technology system of the data subject. The definition of cookies is explained above. The setting of the cookie enables us to analyze the usage of our Portals. Using the data obtained, usage profiles are created. The usage profiles are used to analyze visitor behavior and enable an improvement of our Internet offer. Data collected through the Shopeybd component are not used to identify the data subject without first obtaining separate and explicit consent from the data subject. These data will not be merged with personal data or with other data which contains the same usage profile. By default, Shopeybd identifies the companies, not the individuals, who are accessing the Portals, and presents firmographic information. Personal information is only collected and stored based on opt-in preferences.

With each call-up to one of the individual pages of the Portals, the Internet browser on the information technology system of the data subject is programmatically requested to submit data for online analysis to the Shopeybd component. During this technical procedure, Shopeybd gains knowledge of visitor information, such as the requesting IP address, which inter alia, serves to understand the origin of visitors and clicks.

The cookie is used to store anonymized information, such as the access time, and the frequency of visits to our Portals. With each visit to our Internet pages, these visitor data, including the IP address of the Internet access used by the data subject, are logged and stored by the Shopeybd server.

The data subject may prevent the setting of cookies through our Portals at any time using a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the Internet browser used would also prevent Shopeybd from setting a cookie on the information technology system of the data subject. In addition, cookies already in use by Shopeybd may be deleted at any time via a web browser or other software programs. If Shopeybd chooses “Shopeybd” as the lead identification option for their website, we might transmit personal data of the data subject to our processors. By implementing this lead identification option, the data subject agrees to the transfer of personal data required for lead identification. The personal data transmitted to Shopeybd is usually first name, last name, email address, IP address, telephone number, mobile phone number, or other data necessary for lead identification processing. The transmission of the data is aimed at lead identification. Shopeybd can transfer personal data to our processors, in particular, if a legitimate interest in the product or service is given.

The Portals use cookies. Cookies are text files that are stored in a computer system via an Internet browser.

Many Internet sites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a character string through which Internet pages and servers can be assigned to the specific Internet browser in which the cookie was stored. This allows visited Internet sites and servers to differentiate the individual browser of the subject from other Internet browsers that contain other cookies. A specific Internet browser can be recognized and identified using the unique cookie ID.

Through the use of cookies, Shopeybd can provide the users of the Portals with more user-friendly services that would not be possible without the cookie setting.

Using a cookie, the information and offers on our Portals can be optimized with the user in mind. Cookies allow us, as previously mentioned, to recognize our Portals users. The purpose of this recognition is to make it easier for users to utilize our Portals. The Portal user that uses cookies e.g. does not have to enter access data (login credentials) each time the Portals is accessed, because this is taken over by the Portals, and the cookie is thus stored on the user’s computer system. In other words, it is not necessary to log in again every time a new page is requested (a click). Another example is the cookie of a shopping cart in an online shop. The online store remembers the articles that a customer has placed in the digital shopping cart via a cookie.

The data subject may, at any time, prevent the setting of cookies through our Portals using a corresponding setting of the Internet browser used, and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. If the data subject deactivates the setting of cookies in the Internet browser used, not all functions of our Portals may be entirely usable.

We take reasonable steps to ensure that your personal information is treated securely and to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks.

To prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online. In order to minimise the likelihood of security breaches, we do not publicly disclose the nature of such security measures.

However, please remember that using the Internet always carries the risk of specific security incidents, but we assure you that thanks to the implemented procedures we aim at reducing this risk as much as it is possible, by regular reviews of IT systems and their updates, as well as active monitoring of critical system points.

The Portals of Shopeybd collects a series of general data and information when a data subject or automated system calls up the Portals. This general data and information are stored in the server log files. Collected may be (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our Portals (so-called referrers), (4) the sub-websites, (5) the date and time (so-called timestamp) of access to the Internet site, (6) an Internet protocol address (IP address), (7) the internet service provider (ISP) of the accessing system, and (8) any other similar data and information that may be used in the event of attacks on our information technology systems.

When using these general data and information, Shopeybd does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our Portals correctly, (2) optimize the content of our Portals as well as its advertisement, (3) ensure the long-term viability of our information technology systems and website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, Shopeybd analyzes anonymously collected data and information statistically, to increase the data protection and data security of our enterprise and ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.

The data subject can register on the Portals with the indication of personal data. Which personal data are transmitted by Shopeybd is determined by the respective sign-up form used for the registration which can be obtained from https://www.shopeybd.com/my-account. The personal data entered by the data subject are collected and stored exclusively for internal use by Shopeybd, and his purposes. Shopeybd may request transfer to one or more processors that also use personal data for an internal purpose that is attributable to Shopeybd.

By registering on the Portals of Shopeybd, the IP address—assigned by the internet service provider (ISP) and used by the data subject—date, and time of the registration are also stored. The storage of this data takes place against the background that this is the only way to prevent the misuse of our Services, and, if necessary, to make it possible to investigate committed offenses. Shopeybd stores such data only insofar, as the storage of this data is necessary to secure Shopeybd. This data is not passed on to third parties unless there is a statutory obligation to pass on the data, or if the transfer serves the aim of criminal prosecution.

The registration of the data subject, with the voluntary indication of personal data, is intended to enable Shopeybd to offer the data subject contents or services that may only be offered to registered users due to the nature of the matter in question. Registered persons are free to change the personal data specified during the registration at any time, or to have them completely deleted from the data stock of Shopeybd.

The data controller shall, at any time, provide information upon request to each data subject as to what personal data are stored about the data subject. In addition, the data controller shall correct or erase personal data at the request or indication of the data subject, insofar as there are no statutory storage obligations. A Data Protection Officer particularly designated in this data protection declaration, as well as the entirety of Shopeybd’s employees, are available to the data subject in this respect as contact persons.

On the Portals of Shopeybd, users are allowed to subscribe to our newsletter. The input section used for this purpose determines what personal data are transmitted, as well as when the newsletter is ordered from Shopeybd.

Shopeybd informs its customers and partners regularly using a newsletter about product offers. The enterprise’s newsletter may only be received by the data subject if (1) the data subject has a valid e-mail address and (2) the data subject registers for the newsletter shipping. A confirmation e-mail will be sent to the e-mail address registered by a data subject for the first time for newsletter shipping, for legal reasons, in the double-opt-in procedure. This confirmation e-mail is used to prove whether the owner of the e-mail address as the data subject is authorized to receive the newsletter.

During the registration for the newsletter, we also store the IP address of the computer system assigned by the internet service provider (ISP) and used by the data subject at the time of the registration, as well as the date and time of the registration. The collection of this data is necessary to understand the (possible) misuse of the e-mail address of a data subject at a later date, and it, therefore, serves the aim of the legal protection of Shopeybd.

The personal data collected as part of a registration for the newsletter will only be used to send our newsletter. In addition, subscribers to the newsletter may be informed by e-mail, as long as this is necessary for the operation of the newsletter service or a registration in question, as this could be the case in the event of modifications to the newsletter offer, or the event of a change in technical circumstances. There will be no transfer of personal data collected by the newsletter service to third parties. The subscription to our newsletter may be terminated by the data subject at any time. The consent to the storage of personal data, which the data subject has given for shipping the newsletter, may be revoked at any time. For revocation of consent, a corresponding link (‘unsubscribe’) is found in each newsletter. It is also possible to unsubscribe from the newsletter at any time directly on our Portals or to communicate this to us in a different way.

The newsletter of Shopeybd contains tracking pixels. A tracking pixel is a miniature graphic embedded in such e-mails, which are sent in HTML format to enable log file recording and analysis. This allows a statistical analysis of the success or failure of online marketing campaigns. Based on the embedded tracking pixel, Shopeybd may see if and when an e-mail was opened by a data subject, and which links in the e-mail were called up (clicked on) by data subjects.

Such personal data collected in the tracking pixels contained in the newsletters are stored and analyzed by Shopeybd to optimize the shipping of the newsletter, as well as to continuously adapt the content of future newsletters to the interests of the data subject. These personal data will not be passed on to third parties. Data subjects are at any time entitled to revoke the respective separate declaration of consent issued using the double-opt-in procedure. After a revocation, these personal data will be deleted by Shopeybd. Shopeybd automatically regards a withdrawal from the receipt of the newsletter as a revocation.

The Portals of Shopeybd contains information that enables quick electronic contact with our enterprise, as well as direct communication with us, which also includes a general address of the so-called electronic mail (e-mail address). If a data subject contacts Shopeybd by e-mail or via a contact form, the personal data transmitted by the data subject are automatically stored. Such personal data transmitted voluntarily by a data subject to the data controller are stored for processing or contacting the data subject. There is no transfer of this personal data to third parties.

The comments made in the blog of Shopeybd may be subscribed to by third parties. In particular, there is the possibility that a commenter subscribes to the comments following his comments on a particular blog post.

If a data subject decides to subscribe to the option, Shopeybd will send an automatic confirmation e-mail to check the double opt-in procedure as to whether the owner of the specified e-mail address decided in favor of this option. The option to subscribe to comments may be terminated at any time.

The data controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which Shopeybd is subject to.

If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased under legal requirements.

Right of confirmation
Each data subject shall have the right granted by the European legislator to obtain from Shopeybd the confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact our Data Protection Officer or another employee of Shopeybd.

Right of access
Each data subject shall have the right granted by the European legislator to obtain from Shopeybd free information about his or her data stored at any time and a copy of this information. Furthermore, the European directives and regulations grant the data subject access to the following information:

• the purposes of the processing;
• the categories of personal data concerned;
• the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations;
• where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
• the existence of the right to request from Shopeybd rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing;
• the existence of the right to complain about a supervisory authority;
• where the personal data are not collected from the data subject, any available information as to their source;
• the existence of automated decision-making, including profiling, referred to in Articles 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.

Furthermore, the data subject shall have a right to obtain information as to whether personal data are transferred to a third country or an international organization. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.

If a data subject wishes to avail himself of this right of access, he or she may at any time contact our Data Protection Officer or another employee of Shopeybd.

Right to rectification
Each data subject shall have the right granted by the European legislator to obtain from Shopeybd without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including using providing a supplementary statement.

If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact our Data Protection Officer or another employee of Shopeybd.

Right to erasure (Right to be forgotten)
Each data subject shall have the right granted by the European legislator to obtain from Shopeybd the erasure of personal data concerning him or her without undue delay, and Shopeybd shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:

• Personal data are no longer necessary for the purposes for which they were collected or otherwise processed.
• The data subject withdraws consent to which the processing is based according to point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing.
• The data subject objects to the processing under Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing or the data subject objects to the processing under Article 21(2) of the GDPR.
• The personal data have been unlawfully processed.
• The personal data must be erased for compliance with a legal obligation in Union or Member State law to which Shopeybd is subject.
• The personal data have been collected for the offer of information society services referred to in Article 8(1) of the GDPR.

If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by Shopeybd, he or she may at any time contact our Data Protection Officer or another employee of Shopeybd. The Data Protection Officer of Shopeybd or another employee shall promptly ensure that the erasure request is complied with immediately.

Where Shopeybd has made personal data public and is obliged under Article 17(1) to erase the personal data, Shopeybd, taking account of available technology and the cost of implementation shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required. The Data Protection Officer of Shopeybd or another employee will arrange the necessary measures in individual cases.

Right of restriction of processing
Each data subject shall have the right granted by the European legislator to obtain from Shopeybd the restriction of processing where one of the following applies:

• The accuracy of the personal data is contested by the data subject, for a period enabling Shopeybd to verify the accuracy of the personal data.
• The processing is unlawful and the data subject opposes the erasure of the personal data and requests instead of the restriction of their use instead.
• Shopeybd no longer needs the personal data for processing, but they are required by the data subject for the establishment, exercise, or defense of legal claims.
• The data subject has objected to processing under Article 21(1) of the GDPR pending the verification of whether the legitimate grounds of Shopeybd override those of the data subject.

If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by Shopeybd, he or she may at any time contact our Data Protection Officer or another employee of Shopeybd. The Data Protection Officer of Shopeybd or another employee will arrange the restriction of the processing.

Right to data portability
Each data subject shall have the right granted by the European legislator, to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used, and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from Shopeybd to which the personal data have been provided, as long as the processing is based on consent under point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or a contract under point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or the exercise of official authority vested in Shopeybd.

Furthermore, in exercising his or her right to data portability under Article 20(1) of the GDPR, the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.

To assert the right to data portability, the data subject may at any time contact the Data Protection Officer designated by Shopeybd or another employee.

Right to object
Each data subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to the processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions.
Shopeybd shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights, and freedoms of the data subject, or for the establishment, exercise, or defense of legal claims.

If Shopeybd processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing personal data concerning him or her for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to Shopeybd the processing for direct marketing purposes, the data subject could inform Shopeybd to exclude the subject from any direct marketing approach and Shopeybd will no longer process the personal data for these purposes.

In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to the processing of personal data concerning him or her by Shopeybd for scientific or historical research purposes, or statistical purposes under Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

To exercise the right to object, the data subject may directly contact the Data Protection Officer of Shopeybd or another employee. In addition, the data subject is free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use his or her right to object by automated means using technical specifications.

Automated individual decision-making, including profiling
Each data subject shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is not authorized by Union or Member State law to which Shopeybd is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, or (3) is not based on the data subject’s explicit consent.

If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject’s explicit consent, Shopeybd shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of Shopeybd, to express his or her point of view and contest the decision.

If the data subject wishes to exercise the rights concerning automated individual decision-making, he or she may at any time directly contact our Data Protection Officer of Shopeybd or another employee of Shopeybd.

Right to withdraw data protection consent
Each data subject shall have the right granted by the European legislator to withdraw his or her consent to the processing of his or her data at any time.
If the data subject wishes to exercise the right to withdraw the consent, he or she may at any time directly contact our Data Protection Officer of Shopeybd or another employee of Shopeybd. If such withdrawal of consent would mean that Shopeybd is unable to provide its Services to the data subject, such data subject will be notified of the same before any termination of the Services.

On the Portals, Shopeybd has integrated components of the enterprise Facebook. Facebook is a social network.

A social network is a place for social meetings on the Internet, an online community, which usually allows users to communicate with each other and interact in a digital space. A social network may serve as a platform for the exchange of opinions and experiences, or enable the Internet community to provide personal or business-related information. Facebook allows social network users to include the creation of private profiles, upload photos, and network through friend requests.

The operating company of Facebook is Facebook, Inc., 1 Hacker Way, Menlo Park, CA 94025, United States. If a person lives outside of the United States or Canada, the controller is Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.

With each call-up to one of the individual pages of the Portals, which is operated by Shopeybd and into which a Facebook component (Facebook plug-ins) was integrated, the web browser on the information technology system of the data subject is automatically prompted to download a display of the corresponding Facebook component from Facebook through the Facebook component. An overview of all the Facebook Plug-ins may be accessed under https://developers.facebook.com/docs/plugins/. During this technical procedure, Facebook is made aware of what specific sub-site of our Portals was visited by the data subject.

If the data subject is logged in at the same time on Facebook, Facebook detects with every call-up to our Portals by the data subject—and for the entire duration of their stay on our Internet site—which specific sub-site of our Internet page was visited by the data subject. This information is collected through the Facebook component and associated with the respective Facebook account of the data subject. If the data subject clicks on one of the Facebook buttons integrated into our Portals, e.g. the “Like” button, or if the data subject submits a comment, then Facebook matches this information with the personal Facebook user account of the data subject and stores the personal data.

Facebook always receives, through the Facebook component, information about a visit to our Portals by the data subject, whenever the data subject is logged in at the same time on Facebook during the time of the call-up to our Portals. This occurs regardless of whether the data subject clicks on the Facebook component or not. If such a transmission of information to Facebook is not desirable for the data subject, then he or she may prevent this by logging off from their Facebook account before a call-up to our Portals is made.

The data protection guideline published by Facebook, which is available at https://facebook.com/about/privacy/, provides information about the collection, processing, and use of personal data by Facebook. In addition, it is explained there what setting options Facebook offers to protect the privacy of the data subject.

On the Portals, Shopeybd has integrated the component of Google Analytics. Google Analytics is a web analytics service. Web analytics is the collection, gathering, and analysis of data about the behavior of visitors to Portals. A web analysis service collects, inter alia, data about the Portals from which a person has come (the so-called referrer), which sub-pages were visited, or how often and for what duration a sub-page was viewed. Web analytics are mainly used for the optimization of Portals and to carry out a cost-benefit analysis of Internet advertising.

The operator of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States.

The purpose of the Google Analytics component is to analyze the traffic on our Portals. Google uses the collected data and information, inter alia, to evaluate the use of our Portals and to provide online reports, which show the activities on our Portals, and to provide other services concerning the use of our Portals for us.

Google Analytics places a cookie on the information technology system of the data subject. The definition of cookies is explained above. With the setting of the cookie, Google is enabled to analyze the use of our Portals. With each call-up to one of the individual pages of this Internet site, which is operated by Shopeybd and into which a Google Analytics component was integrated, the Internet browser on the information technology system of the data subject will automatically submit data through the Google Analytics component for online advertising and the settlement of commissions to Google. During this technical procedure, the enterprise Google gains knowledge of personal information, such as the IP address of the data subject, which serves Google, inter alia, to understand the origin of visitors and clicks, and subsequently create commission settlements.

The cookie is used to store personal information, such as the access time, the location from which the access was made, and the frequency of visits of our Portals by the data subject. With each visit to our Internet site, such personal data, including the IP address of the Internet access used by the data subject, will be transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties.

The data subject may, as stated above, prevent the setting of cookies through our Portals at any time using a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the Internet browser used would also prevent Google Analytics from setting a cookie on the information technology system of the data subject. In addition, cookies already in use by Google Analytics may be deleted at any time via a web browser or other software programs.

In addition, the data subject has the possibility of objecting to a collection of data that are generated by Google Analytics, which is related to the use of these Portals, as well as the processing of this data by Google and the chance to preclude any such. For this purpose, the data subject must download a browser add-on under the link https://tools.google.com/dlpage/gaoptout and install it. This browser add-on tells Google Analytics through JavaScript, that any data and information about the visits of Internet pages may not be transmitted to Google Analytics. The installation of the browser add-ons is considered an objection by Google. If the information technology system of the data subject is later deleted, formatted, or newly installed, then the data subject must reinstall the browser add-ons to disable Google Analytics. If the browser add-on was uninstalled by the data subject or any other person who is attributable to their sphere of competence, or is disabled, it is possible to execute the reinstallation or reactivation of the browser add-ons.

Further information and the applicable data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/ and http://www.google.com/analytics/terms/us.html. Google Analytics is further explained under the following link https://www.google.com/analytics/.

On these Portals, Shopeybd has integrated Google Remarketing services. Google Remarketing is a feature of Google AdWords, which allows an enterprise to display advertising to Internet users who have previously resided on the enterprise’s Internet site. The integration of Google Remarketing, therefore, allows an enterprise to create user-based advertising and thus shows relevant advertisements to interested Internet users.

The operating company of the Google Remarketing services is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States.

The purpose of Google Remarketing is the insertion of interest-relevant advertising. Google Remarketing allows us to display ads on the Google network or on other Portals, which are based on individual needs and matched to the interests of Internet users.

Google Remarketing sets a cookie on the information technology system of the data subject. The definition of cookies is explained above. With the setting of the cookie, Google enables a recognition of the visitor of our Portals if he calls up consecutive web pages, which are also a member of the Google advertising network. With each call-up to an Internet site on which the service has been integrated by Google Remarketing, the web browser of the data subject identifies automatically with Google. During this technical procedure, Google receives personal information, such as the IP address or the surfing behavior of the user, which Google uses, inter alia, for the insertion of interest-relevant advertising.

The cookie is used to store personal information, e.g. the Internet pages visited by the data subject. Each time we visit our Internet pages, personal data, including the IP address of the Internet access used by the data subject, is transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties.

The data subject may, as stated above, prevent the setting of cookies through our Portals at any time using a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the Internet browser used would also prevent Google from setting a cookie on the information technology system of the data subject. In addition, cookies already in use by Google may be deleted at any time via a web browser or other software programs.

In addition, the data subject has the possibility of objecting to the interest-based advertising by Google. For this purpose, the data subject must call up the link to www.google.de/settings/ads and make the desired settings on each Internet browser used by the data subject.

Further information and the actual data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/.

On the Portals, Shopeybd has integrated Google AdWords. Google AdWords is a service for Internet advertising that allows the advertiser to place ads in Google search engine results and the Google advertising network. Google AdWords allows an advertiser to pre-define specific keywords with the help of which an ad on Google’s search results is only then displayed when the user utilizes the search engine to retrieve a keyword-relevant search result. In the Google Advertising Network, the ads are distributed on relevant web pages using an automatic algorithm, taking into account the previously defined keywords.

The operating company of Google AdWords is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, UNITED STATES.

The purpose of Google AdWords is the promotion of our Portals by the inclusion of relevant advertising on the Portals of third parties and in the search engine results of the search engine Google and an insertion of third-party advertising on our Portals.

If a data subject reaches our Portals via a Google ad, a conversion cookie is filed on the information technology system of the data subject through Google. The definition of cookies is explained above. A conversion cookie loses its validity after 30 days and is not used to identify the data subject. If the cookie has not expired, the conversion cookie is used to check whether certain sub-pages, e.g, the shopping cart from an online shop system, were called up on our Portals. Through the conversion cookie, both Google and Shopeybd can understand whether a person who reached an AdWords ad on our Portals generated sales, that is, executed or canceled a sale of goods.

The data and information collected through the use of the conversion cookie are used by Google to create visit statistics for our Portals. These visit statistics are used to determine the total number of users who have been served through AdWords ads to ascertain the success or failure of each AdWords ad and to optimize our AdWords ads in the future. Neither our company nor other Google AdWords advertisers receive information from Google that could identify the data subject.

The conversion cookie stores personal information, e.g. the Internet pages visited by the data subject. Each time we visit our Internet pages, personal data, including the IP address of the Internet access used by the data subject, is transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties.

The data subject may, at any time, prevent the setting of cookies by our Portals, as stated above, using a corresponding setting of the Internet browser used and thus permanently deny the setting of cookies. Such a setting of the Internet browser used would also prevent Google from placing a conversion cookie on the information technology system of the data subject. In addition, a cookie set by Google AdWords may be deleted at any time via the Internet browser or other software programs.

The data subject has a possibility of objecting to the interest-based advertisement of Google. Therefore, the data subject must access from each of the browsers by using the link www.google.de/settings/ads and setting the desired settings.

Further information and the applicable data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/.

Shopeybd has integrated components of the LinkedIn Corporation on these Portals. LinkedIn is a web-based social network that enables users with existing business contacts to connect and make new business contacts. LinkedIn is currently the largest platform for business contacts and one of the most visited Portals in the world.

The operating company of LinkedIn is LinkedIn Corporation, 2029 Stierlin Court Mountain View, CA 94043, UNITED STATES. For privacy matters outside of the UNITED STATES LinkedIn Ireland, Privacy Policy Issues, Wilton Plaza, Wilton Place, Dublin 2, Ireland, is responsible.

With each call-up to one of the individual pages of this Internet site, which is operated by Shopeybd and on which a LinkedIn component (LinkedIn plug-in) was integrated, the Internet browser on the information technology system of the data subject is automatically prompted to the download of a display of the corresponding LinkedIn component of LinkedIn. Further information about the LinkedIn plug-in may be accessed under https://developer.linkedin.com/plugins. During this technical procedure, LinkedIn gains knowledge of what specific sub-page of our Portals was visited by the data subject.

If the data subject is logged in at the same time on LinkedIn, LinkedIn detects with every call-up to our Portals by the data subject—and for the entire duration of their stay on our Internet site—which specific sub-page of our Internet page was visited by the data subject. This information is collected through the LinkedIn component and associated with the respective LinkedIn account of the data subject. If the data subject clicks on one of the LinkedIn buttons integrated on our Portals, then LinkedIn assigns this information to the personal LinkedIn user account of the data subject and stores the personal data.

LinkedIn receives information via the LinkedIn component that the data subject has visited our Portals, provided that the data subject is logged in at LinkedIn at the time of the call-up to our Portals. This occurs regardless of whether the person clicks on the LinkedIn button or not. If such a transmission of information to LinkedIn is not desirable for the data subject, then he or she may prevent this by logging off from their LinkedIn account before a call-up to our Portals is made.

LinkedIn provides under https://www.linkedin.com/psettings/guest-controls the possibility to unsubscribe from e-mail messages, SMS messages, and targeted ads, as well as the ability to manage ad settings. LinkedIn also uses affiliates such as Eire, Google Analytics, BlueKai, DoubleClick, Nielsen, Comscore, Eloqua, and Lotame. The setting of such cookies may be denied under https://www.linkedin.com/legal/cookie-policy. The applicable privacy policy for LinkedIn is available at https://www.linkedin.com/legal/privacy-policy. The LinkedIn Cookie Policy is available at https://www.linkedin.com/legal/cookie-policy.

On the Portals, Shopeybd has integrated components of Twitter. Twitter messages (tweets) are available for everyone, including those who are not logged on to Twitter. The tweets are also displayed to so-called followers of the respective user. Followers are other Twitter users who follow a user’s tweets. Furthermore, Twitter allows data subjects to address a wide audience via hashtags, links, or retweets.

The operating company of Twitter is Twitter, Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, UNITED STATES.

With each call-up to one of the individual pages of this Internet site, which is operated by Shopeybd and on which a Twitter component (Twitter button) was integrated, the Internet browser on the information technology system of the data subject is automatically prompted to download a display of the corresponding Twitter component of Twitter. Further information about the Twitter buttons is available under https://about.twitter.com/de/resources/buttons. During this technical procedure, Twitter gains knowledge of what specific sub-page of our Portals was visited by the data subject. The purpose of the integration of the Twitter component is a retransmission of the contents of this website to allow our users to introduce this web page to the digital world and increase our visitor numbers.

If the data subject is logged in at the same time on Twitter, Twitter detects with every call-up to our Portals by the data subject and for the entire duration of their stay on our Internet site which specific sub-page of our Internet page was visited by the data subject. This information is collected through the Twitter component and associated with the respective Twitter account of the data subject. If the data subject clicks on one of the Twitter buttons integrated on our Portals, then Twitter assigns this information to the personal Twitter user account of the data subject and stores the personal data.

Twitter receives information via the Twitter component that the data subject has visited our Portals, provided that the data subject is logged in on Twitter at the time of the call-up to our Portals. This occurs regardless of whether the person clicks on the Twitter component or not. If such a transmission of information to Twitter is not desirable for the data subject, then he or she may prevent this by logging off from their Twitter account before a call-up to our Portals is made. The applicable data protection provisions of Twitter may be accessed under https://twitter.com/privacy?lang=en.

Art. 6(1) lit. a GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is a party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service, the processing is based on Article 6(1) lit. b GDPR. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services. If our company is subject to a legal obligation by which processing of personal data is required, such as for the fulfillment of tax obligations, the processing is based on Art. 6(1) lit. c GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or another natural person. This would be the case, for example, if a visitor were injured in our company and his name, age, health insurance data, or other vital information would have to be passed on to a doctor, hospital, or other third parties. Then the processing would be based on Art. 6(1) lit. d GDPR. Finally, processing operations could be based on Article 6(1) lit. f GDPR. This legal basis is used for processing operations that are not covered by any of the abovementioned legal grounds, if the processing is necessary for the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. Such processing operations are particularly permissible because they have been specifically mentioned by the European legislator. He considered that a legitimate interest could be assumed if the data subject is a client of Shopeybd (Recital 47 Sentence 2 GDPR).

Where the processing of personal data is based on Article 6(1) of GDPR our legitimate interest is to carry out our business in favor of the well-being of all our employees and the shareholders while maintaining our obligations;

• to prevent fraud by using personal information to prevent and detect fraud and abuse to protect the security of our customers, Shopeybd, and others. We may also use scoring methods to assess and manage credit risks;
• to ensure anti-money laundering compliance through verification to minimize fraud and also to prevent the creation and the use of fraudulent accounts;
• to ensure network and information security by utilizing a wide variety of programs that validate our security controls;
• to identify criminal or suspicious transactions or threats to public safety;
• to improve or enhance the operations of Shopeybd, and the Services provided by Shopeybd to data subjects, and
• to learn about and understand the data subject’s behavior or any other customers of Shopeybd to our Services.

The criteria used to determine the period of storage of personal data is the respective statutory retention period. After the expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfillment of the contract or the initiation of a contract.

We clarify that the provision of personal data may be required by law (e.g. tax regulations) or may also result from contractual provisions (e.g. information on the contractual partner). Sometimes it may be necessary to conclude a contract that the data subject provides us with personal data, which must subsequently be processed by us. The data subject is, for example, obliged to provide us with personal data when our company signs a contract with him or her. The non-provision of the personal data would have the consequence that the contract with the data subject could not be concluded. Before personal data is provided by the data subject, the data subject must contact our Data Protection Officer. Our Data Protection Officer clarifies to the data subject whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data, and the consequences of non-provision of the personal data.