DATA PROTECTION

This privacy policy clarifies the nature, scope and purpose of the processing of personal data (hereinafter referred to as "data") within our online offer and the associated websites, functions and content as well as external online presences, such as our social media profile. (hereinafter collectively referred to as "online offer"). With regard to the terms used, such as "processing" or "controller", we refer to the definitions in Art. 4 of the General Data Protection Regulation (GDPR).

Responsible:
Company.: LU REN GmbH
Street No.: THUILLESTRASSE 50
Postcode, City: 81247 Munich
Country: Germany
HRB 233041
Managing Director: Ji Hong
Telephone number: +49 8152 9981399
E-mail address: [email protected]

Types of data processed:

- Inventory data (e.g., names, addresses).
- Contact data (e.g., e-mail, telephone numbers).
- Content data (e.g., text entries, photographs, videos).
- Contract data (e.g., subject matter of the contract, term, customer category).
- Payment data (e.g., bank details, payment history), bank details, payment history).
- Usage data (e.g., websites visited, interest in content, access times).
- Meta/communication data (e.g., device information, IP addresses).

Processing of special categories of data (Art. 9 (1) GDPR):

No special categories of data are processed.

Categories of data subjects affected by the processing:

- Visitors and users of the online offer.
In the following, we also refer to the data subjects collectively as "users".

Purpose of the processing:

- Provision of the online offer, its content and store functions.
- Provision of contractual services, service and customer care.
- Answering contact inquiries and communicating with users.

Status: 03/2021

1. terms used
1.1 "Personal data" means any information relating to an identified or identifiable natural person (hereinafter referred to as "data subject"); an identifiable natural person is one who 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 (e.g. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

1.2 "Processing" means any operation or set of operations which is performed on personal data, whether or not by automated means. The term is broad and covers practically any handling of data.

1.3 "Controller" means 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.

2. relevant legal bases
In accordance with Art. 13 GDPR, we inform you of the legal bases of our data processing. If the legal basis is not stated in the privacy policy, the following applies: The legal basis for obtaining consent is Art. 6 para. 1 lit. a and Art. 7 GDPR, the legal basis for processing for the performance of our services and implementation of contractual measures as well as responding to inquiries is Art. 6 para. 1 lit. b GDPR, the legal basis for processing to fulfil our legal obligations is Art. 6 para. 1 lit. c GDPR, and the legal basis for processing to protect our legitimate interests is Art. 6 para. 1 lit. f GDPR. In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 para. 1 lit. d GDPR serves as the legal basis.

3. changes and updates to the privacy policy
We ask you to inform yourself regularly about the content of our privacy policy. We will adapt the privacy policy as soon as changes to the data processing carried out by us make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or other individual notification.

4. security measures
4.1 We take security measures in accordance with Art. 32 GDPR, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, appropriate technical and organizational measures to ensure a level of security appropriate to the risk; the measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as the access, input, disclosure, safeguarding of availability and their separation. Furthermore, we have established procedures that ensure the exercise of data subject rights, the deletion of data and the response to data threats. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and procedures, in accordance with the principle of data protection through technology design and data protection-friendly default settings (Art. 25 GDPR).

4.2 The security measures include, in particular, the encrypted transmission of data between your browser and our server.

5 Disclosure and transfer of data
5.1 If we disclose data to other persons and companies (processors or third parties) as part of our processing, transfer it to them or otherwise grant them access to the data, this will only be done on the basis of legal permission (e.g. if the data is transferred to third parties, such as payment service providers, in accordance with Art. 6 Para. 1 lit. b GDPR), you have given your consent, a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, hosting providers, tax, business and legal advisors, customer care, accounting, billing and similar services that allow us to efficiently and effectively fulfill our contractual obligations, administrative tasks and duties).

5.2 If we commission third parties with the processing of data on the basis of a so-called "order processing contract", this is done on the basis of Art. 28 GDPR.

6. transfers to third countries
If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if this occurs in the context of the use of third-party services or disclosure or transfer of data to third parties, this will only take place if it is done to fulfill our (pre)contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we only process or have the data processed in a third country if the special requirements of Art. 44 et seq. GDPR are met. This means, for example, that the processing takes place on the basis of special guarantees, such as the officially recognized determination of a level of data protection corresponding to the EU (e.g. for the USA through the "Privacy Shield") or compliance with officially recognized special contractual obligations (so-called "standard contractual clauses").

7. rights of data subjects
7.1 You have the right to request confirmation as to whether the data in question is being processed and to request information about this data as well as further information and a copy of the data in accordance with Art. 15 GDPR.

7.2 You have according to. Art. 16 GDPR, you have the right to request the completion of data concerning you or the rectification of inaccurate data concerning you.

7.3 In accordance with Art. 17 GDPR, you have the right to demand that the data in question be deleted immediately or, alternatively, to demand a restriction on the processing of the data in accordance with Art. 18 GDPR.

7.4 You have the right to request to receive the data concerning you that you have provided to us in accordance with Art. 20 GDPR and to request its transfer to other data controllers.

7.5 You also have the right to lodge a complaint with the competent supervisory authority in accordance with Art. 77 GDPR.

8. right of revocation
You have the right to revoke consents granted in accordance with Art. 7 para. 3 GDPR with effect for the future.

9. right to object
You can object to the future processing of data concerning you at any time in accordance with Art. 21 GDPR. In particular, you may object to processing for direct marketing purposes.

10. cookies and right to object to direct advertising
10.1 "Cookies" are small files that are stored on users' computers. Different information can be stored within the cookies. A cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or after their visit to an online service. Temporary cookies, or "session cookies" or "transient cookies", are cookies that are deleted after a user leaves an online service and closes their browser. The content of a shopping cart in an online store or a login status, for example, can be stored in such a cookie. Cookies that remain stored even after the browser is closed are referred to as "permanent" or "persistent". For example, the login status can be saved if the user visits the website after several days. The interests of users can also be stored in such a cookie and used for reach measurement or marketing purposes. "Third-party cookies" are cookies from providers other than the controller who operates the online service (otherwise, if they are only the controller's cookies, they are referred to as "first-party cookies").

10.2 We use temporary and permanent cookies and provide information about this in our privacy policy. If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.

10.3 A general objection to the use of cookies used for online marketing purposes can be declared for a large number of services, especially in the case of tracking, via the US website http://www.aboutads.info/choices/ or the EU website http://www.youronlinechoices.com/. Furthermore, the storage of cookies can be achieved by deactivating them in the browser settings. Please note that you may then not be able to use all the functions of this website.

11. deletion of data
11.1 The data processed by us will be deleted or restricted in their processing in accordance with Art. 17 and 18 GDPR. Unless expressly stated in this privacy policy, the data stored by us will be deleted as soon as it is no longer required for its intended purpose and the deletion does not conflict with any statutory retention obligations. If the data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.

11.2 Germany: In accordance with legal requirements, storage is carried out in particular for 6 years in accordance with Section 257 (1) HGB (trading books, inventories, opening balance sheets, annual financial statements, commercial letters, accounting documents, etc.) and for 10 years in accordance with Section 147 (1) AO (books, records, management reports, accounting documents, commercial and business letters, documents relevant for taxation, etc.)

12. order processing in the online store and customer account
12.1 We process the data of our customers as part of the ordering processes in our online store in order to enable them to select and order the selected products and services, as well as their payment and delivery, or execution.

12.2 The processed data includes inventory data, communication data, contract data, payment data and the data subjects include our customers, interested parties and other business partners. The processing is carried out for the purpose of providing contractual services in the context of operating an online store, billing, delivery and customer services. We use session cookies to store the contents of the shopping cart and permanent cookies to store the login status.

12.3 The processing is carried out on the basis of Art. 6 para. 1 lit. b (execution of order processes) and c (legally required archiving) GDPR. The information marked as necessary is required to justify and fulfill the contract. We only disclose the data to third parties in the context of delivery, payment or within the scope of legal permissions and obligations towards legal advisors and authorities. The data will only be processed in third countries if this is necessary for the fulfillment of the contract (e.g. at the customer's request for delivery or payment).

12.4 Users can optionally create a user account in which they can view their orders in particular. As part of the registration process, users will be provided with the required mandatory information. The user accounts are not public and cannot be indexed by search engines. If users have terminated their user account, their data will be deleted with regard to the user account, subject to their retention is necessary for commercial or tax law reasons in accordance with Art. 6 para. 1 lit. c GDPR. Information in the customer account remains until its deletion with subsequent archiving in the event of a legal obligation. It is the responsibility of users to back up their data before the end of the contract in the event of termination.

12.5 As part of the registration and renewed logins as well as the use of our online services, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests as well as those of the user in protection against misuse and other unauthorized use. This data is not passed on to third parties unless it is necessary to pursue our claims or there is a legal obligation to do so in accordance with Art. 6 para. 1 lit. c GDPR.

12.6 The deletion takes place after the expiry of statutory warranty and comparable obligations, the necessity of storing the data is reviewed every three years; in the case of statutory archiving obligations, the deletion takes place after their expiry (end of commercial law (6 years) and tax law (10 years) retention obligation); information in the customer account remains until its deletion.

13. credit information
13.1 If we make advance payments (e.g. when purchasing on account), we reserve the right to obtain identity and credit information for the purpose of assessing the credit risk on the basis of mathematical-statistical procedures from specialized service companies (credit agencies) in order to safeguard our legitimate interests.

13.2 As part of the credit report, we transmit the following personal data of the customer (name, postal address, date of birth, information on the type of contract, bank details [please specify further data if necessary]) to the following credit agencies:
[Please specify the credit agencies here, e.g.:] SCHUFA-Gesellschaft (SCHUFA Holding AG, Kormoranweg 5, 65201 Wiesbaden), data protection information: https://www.schufa.de/de/ueber-uns/daten-scoring/.

13.3 We process the information received from the credit agencies on the statistical probability of a payment default as part of an appropriate discretionary decision on the establishment, execution and termination of the contractual relationship. We reserve the right to refuse payment on account or any other advance payment in the event of a negative result of the credit check.

13.4 The decision as to whether we make advance payments is made in accordance with Art. 22 GDPR solely on the basis of an automated decision in individual cases, which our software makes on the basis of the information provided by the credit agency.

13.5 If we obtain express consent from you, the legal basis for the credit report and the transmission of the customer's data to the credit agencies is consent pursuant to Art. 6 para. 1 lit. a, 7 GDPR. If no consent is obtained, our legitimate interests in the security of your payment claim are the legal basis in accordance with Art. 6 para. 1 lit. f. GDPR.

14. contact and customer service
14.1 When contacting us (via contact form or e-mail), the user's details are processed to process the contact request and its handling in accordance with Art. 6 para. 1 lit. b) GDPR.

14.2 User data may be stored in our Customer Relationship Management System ("CRM System") or comparable inquiry organization.

14.3 We delete the requests if they are no longer required. We review the necessity every two years; we store inquiries from customers who have a customer account permanently and refer to the details of the customer account for deletion. Furthermore, the statutory archiving obligations apply.

15. collection of access data and log files
15.1 We collect on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. GDPR. GDPR, we collect data about every access to the server on which this service is located (so-called server log files). The access data includes the name of the website accessed, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page), IP address and the requesting provider.

15.2 Log file information is stored for security reasons (e.g. to clarify acts of abuse or fraud) for a maximum of seven days and then deleted. Data whose further storage is required for evidentiary purposes is excluded from deletion until the respective incident has been finally clarified.

16. online presences in social media
16.1 On the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. GDPR. GDPR, we maintain online presences within social networks and platforms in order to communicate with customers, interested parties and users active there and to inform them about our services. When accessing the respective networks and platforms, the terms and conditions and data processing guidelines of their respective operators apply.

16.2 Unless otherwise stated in our privacy policy, we process users' data if they communicate with us within social networks and platforms, e.g. write posts on our online presences or send us messages.

17. communication by post, e-mail, fax or telephone
17.1 We use means of remote communication, such as post, telephone or e-mail, for business transactions and marketing purposes. In doing so, we process inventory data, address and contact data as well as contract data of customers, participants, interested parties and communication partners.

17.2 Processing is carried out on the basis of Art. 6 para. 1 lit. a, Art. 7 GDPR, Art. 6 para. 1 lit. f GDPR in conjunction with legal requirements for advertising communications. Contact is only made with the consent of the contact partners or within the scope of legal permissions and the processed data is deleted as soon as it is no longer required and otherwise with objection/revocation or discontinuation of the basis for authorization or legal archiving obligations.

18. integration of third-party services and content
18.1 We use content or service offers from third-party providers within our online offer on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. GDPR). GDPR) content or service offers from third-party providers in order to integrate their content and services, such as videos or fonts (hereinafter uniformly referred to as "content"). This always presupposes that the third-party providers of this content are aware of the IP address of the user, as they would not be able to send the content to their browser without the IP address. The IP address is therefore required to display this content. We endeavor to only use content whose respective providers only use the IP address to deliver the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. Pixel tags can be used to analyze information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user's device and may contain, among other things, technical information about the browser and operating system, referring websites, time of visit and other information about the use of our online offer, as well as being linked to such information from other sources.

18.2 The following presentation provides an overview of third-party providers and their content, together with links to their data protection declarations, which contain further information on the processing of data and, in some cases already mentioned here, options for objection (so-called opt-out)

- If our customers use third-party payment services (e.g. Stripe, PayPal or Sofortüberweisung), the terms and conditions and data protection notices of the respective third-party providers, which can be accessed within the respective websites or transaction applications, apply.

- Functions of the Instagram service are integrated into our online offering. These functions are offered by Instagram Inc, 1601 Willow Road, Menlo Park, CA, 94025, USA. If you are logged into your Instagram account, you can link the content of our pages to your Instagram profile by clicking on the Instagram button. This allows Instagram to associate your visit to our pages with your user account. We would like to point out that, as the provider of the pages, we have no knowledge of the content of the transmitted data or its use by Instagram. Privacy policy: http://instagram.com/about/legal/privacy/.