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Homepage / WhatsApp Privacy Notice

Privacy Notice for Communication via WhatsApp Business

1. Communication via WhatsApp

We offer you the option to communicate with us via the WhatsApp Business messaging service. Contacting us through WhatsApp is voluntary. Alternatively, you may contact us by email, telephone, or postal mail.

When you communicate with us via WhatsApp, we process the personal data you provide insofar as this is necessary to handle your inquiry, initiate a contractual relationship, or perform an existing contract.

2. Data Controller

The controller responsible for the processing of personal data in connection with communication via WhatsApp is:

Tuzzi Collection GmbH
Hans-Hofmann-Straße 11
95213 Münchberg
Germany

Phone: +49 9251 447 0

Data Protection Officer:
Projekt 29 GmbH & Co. KG
anfrage@projekt29.de

3. What Personal Data Is Processed?

When communicating via WhatsApp, the following personal data may be processed in particular:

  • Your telephone number or the number linked to your WhatsApp account,
  • Your WhatsApp profile name and any other profile information you provide,
  • The content of messages exchanged with us,
  • Images, videos, documents, or other files you send to us,
  • Information regarding the date and time of communication,
  • Any additional information you voluntarily provide during communication.

Please avoid sending special categories of personal data within the meaning of Art. 9 GDPR or particularly confidential information via WhatsApp unless this is necessary for your request.

4. Purposes of Processing

We process personal data transmitted via WhatsApp for the following purposes in particular:

  • Handling and responding to customer and prospective customer inquiries,
  • Communication in connection with orders and deliveries,
  • Providing advice regarding our products and services,
  • Processing complaints and other customer concerns,
  • Carrying out pre-contractual measures,
  • Performing and administering existing contractual relationships,
  • General customer support and service,
  • Compliance with statutory retention and documentation obligations, where applicable.

Any use of data transmitted via WhatsApp for other purposes will only take place where a valid legal basis under data protection law exists.

5. Legal Bases for Processing

Depending on the specific purpose of the communication, the processing of your personal data is based on the following legal grounds:

Art. 6(1)(b) GDPR
Where processing is necessary for the performance of a contract with you or in order to take steps at your request prior to entering into a contract.

Art. 6(1)(c) GDPR
Where processing is necessary for compliance with a legal obligation.

Art. 6(1)(f) GDPR
Where processing is necessary for the purposes of our legitimate interests and these are not overridden by your interests or fundamental rights and freedoms. Our legitimate interest lies in efficient, modern, and customer-friendly communication as well as in the handling and documentation of customer inquiries.

Art. 6(1)(a) GDPR
Where you have provided consent to a specific processing activity.

Where processing is based on your consent, you may withdraw that consent at any time with effect for the future. The lawfulness of processing carried out before the withdrawal remains unaffected.

6. WhatsApp Business as a Communication Service

We use WhatsApp Business for communication.

For users in the European region, the service is provided by WhatsApp Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. WhatsApp is part of the Meta group of companies.

When using WhatsApp, personal data is also processed by WhatsApp and companies working with WhatsApp. We have only limited influence over such processing.

According to WhatsApp, personal messages and calls are generally protected by end-to-end encryption. However, WhatsApp also processes additional information, such as account, usage, device, and connection information, as well as information about how the service is used.

Further information on WhatsApp's processing of personal data can be found in WhatsApp's current Privacy Policy:

https://www.whatsapp.com/legal/privacy-policy-eea

7. Recipients and Further Processing

Within our company, only those persons who are responsible for handling your inquiry will have access to communications conducted via WhatsApp.

Where necessary for the operation of our IT infrastructure and the processing of communications, IT and technical service providers engaged by us may also have access to personal data. Such service providers are engaged in accordance with applicable data protection requirements.

In addition, WhatsApp may transfer personal data to or process personal data with further service providers, companies within the Meta group, or other recipients as part of providing its services. Details can be found in WhatsApp's Privacy Policy.

8. Transfers to Third Countries

As part of the provision of WhatsApp, personal data may also be transferred to and processed in countries outside the European Economic Area (EEA).

In its current Privacy Policy, WhatsApp states that, due to its global operations, processing may take place through companies and service providers located outside the EEA, particularly in the United States. The data protection mechanisms and safeguards applicable to such transfers are described by WhatsApp.

Please note that communication via WhatsApp may therefore involve data transfers over which we do not have complete control.

9. Retention Period

We generally store personal data arising from WhatsApp communications only for as long as necessary to process the respective inquiry.

If the communication results in a contractual relationship or if statutory retention obligations apply, the relevant data may be retained for the duration of the applicable statutory retention period and, where necessary, beyond that period for the establishment, exercise, or defense of legal claims.

After the applicable retention or storage periods have expired, the data will be deleted unless another legal basis for storage exists.

10. Voluntary Use of WhatsApp

The use of WhatsApp to contact us is entirely voluntary.

If you do not wish to use WhatsApp, you may alternatively contact us via:

  • Email,
  • Telephone, or
  • Postal mail.

Choosing not to use WhatsApp will generally not result in any disadvantages for you. Only the method or speed of communication may differ.

11. Your Rights

Subject to the applicable legal requirements, you have the following rights in particular:

  • Right of access to the personal data concerning you that we process (Art. 15 GDPR),
  • Right to rectification of inaccurate personal data (Art. 16 GDPR),
  • Right to erasure of personal data (Art. 17 GDPR),
  • Right to restriction of processing (Art. 18 GDPR),
  • Right to data portability (Art. 20 GDPR),
  • Right to object to certain processing activities (Art. 21 GDPR),
  • Right to withdraw consent at any time with effect for the future.

Where processing is based on Art. 6(1)(f) GDPR, you have the right to object at any time on grounds relating to your particular situation. Where personal data is processed for direct marketing purposes, you have the right to object at any time.

12. Right to Lodge a Complaint with a Supervisory Authority

Pursuant to Art. 77 GDPR, you have the right to lodge a complaint with a data protection supervisory authority if you believe that the processing of your personal data violates applicable data protection laws.

You may lodge such a complaint in particular with the supervisory authority responsible for your place of residence, place of work, or the place of the alleged infringement.