Privacy Policy

Responsible party pursuant to data protection laws, in particular the EU General Data Protection Regulation (GDPR), is

circular.fashion UG
(haftungsbeschränkt)

Skalitzer Strasse 97
10997, Berlin
Germany

Tax ID Number: DE 317619011
Managing Director: Ina Budde
Commercial Register Number: HRB 195158 B, Amtsgericht Charlottenburg (Berlin)

Contact:
team@circular.fashion

Your rights as the data subject

You can exercise the following rights at any time by contacting us via e-mail at team@circular.fashion Information on your data stored by us and the processing thereof (Art. 15 GDPR), Rectification of inaccurate personal data (Art. 16 GDPR), Deletion of your data stored by us (Art. 17 GDPR), Restriction of the data processing, provided that we may not delete your data due to legal obligations (Art. 18 GDPR), Objection to the processing of your data with us (Art. 21 GDPR), and Data portability, provide that you have consented to the data processing or have entered into a contract with us (Art. 20 GDPR). If you have given us consent, you may withdraw it at any time, which will remain in effect in the future. You can contact a supervisory authority with a complaint at any time, e.g. the supervisory authority of the state of your residence or the authority that oversees us as the responsible party. You’ll find a list of supervisory authorities (for the non-public area) with their respective addresses at: https://www.bfdi.bund.en/en/Infothek/Anschriften_Links/anschriften_links-node.html.

Collecting general information during a visit to our website

Type and purpose of the processing
When you access our website – i.e. if you do not register or submit information – information of a general nature will be collected automatically. This information (server log files) contains the type of web browser, the operating system used, the domain name of your Internet service provider, your IP address and the like. It is processed in particular for the following purposes: Ensuring an unproblematic website connection, Ensuring seamless use of our website, Analysis of system security and stability, as well as For additional administrative purposes. We will not use your data to draw conclusions about your person. This type of information will be statistically analysed by us if necessary to optimise our website and its underlying technology.

Legal basis
The processing occurs according to Art. 6 Para. 1 (f) GDPR, based on our legitimate interest in improving the stability and functionality of our website.

Recipients
Recipients of the data may be technical service providers, who work on the operation and maintenance of our website as the processor.

Retention period
The data will be deleted as soon as they are no longer required for the reason they were collected. This is generally the case, after the respective session has ended, for data that are used to make the website available.

Mandatory or required provision
The provision of the aforementioned personal data is neither legally nor contractually mandatory. Without the IP address however, the service and functionality of our website are not guaranteed. Furthermore, individual services can be unavailable or limited. For this reason, an objection is excluded.

Cookies

Type and purpose of the processing
Like many other websites, we use so-called ‘cookies’. Cookies are small text files that are stored on your device (laptop, tablet, smartphone, etc.) when you visit our website. With cookies, we receive certain information such as IP address, type of browser and operating system used. Cookies cannot be used to start programs or to transmit viruses to a computer. Based on the information contained in cookies, we can facilitate your navigation of our site and properly display our webpages for you. The data collected by us will not be shared with third parties under any circumstances nor will a link to personal data be created without your consent. Of course, you can view our website without cookies. Internet browsers are regularly configured to accept cookies. In general, you can disable the use of cookies via your browser settings at any time. Please use your internet browser's help function to learn how to change these settings, and keep in mind that individual features of our website may not work if you have disabled the use of cookies.

Retention period and cookies used
If you allow us to use cookies, via your browser settings or consent, the following cookies may be utilised on our web pages such as but not limited to:

Matomo website analytics
Session authentication (logged-in users only)
Cookie preferences

In the following sections, we provide you with information concerning how these cookies can (also) pertain to personal data.
In your browser settings, you can delete individual cookies or the entire set of cookies. You will also find information and instructions on how to delete these cookies or prevent them from being saved in advance. The following links provide the information you’ll need for the respective browser providers:

Mozilla Firefox: https://support.mozilla.org/en-US/kb/delete-cookies-remove-info-websites-stored
Internet Explorer: https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies
Google Chrome: https://support.google.com/accounts/answer/61416?hl=en
Opera: https://www.opera.com/o/ie-simple
Safari: https://support.apple.com/kb/PH17191?locale=de_DE&viewlocale=en_US

Recipients
Recipients of the data may be technical service providers, who work on the operation and maintenance of our website as the processor.

Retention period
The data will be deleted as soon as they are no longer required for the reason they were collected. This is generally the case, after the respective session has ended, for data that are used to make the website available.

Mandatory or required provision
The provision of the aforementioned personal data is neither legally nor contractually mandatory. Without the IP address however, the service and functionality of our website are not guaranteed. Furthermore, individual services can be unavailable or limited. For this reason, an objection is excluded.

Registration on our website

Type and purpose of the processing
Some of our services are only accessible to registered users, such as the Circular Material Library, the Circular Design Software. With the registration to use our personalised services, personal data are collected and need to be submitted by you in the respective registration form. The following data are required for us to grant access to you to our personalised services:

Name
Email address
Password
Phone number (optional)
Company sector
Company name and address
Company department (optional)
Company website
Chosen user group

The user must complete the registration process by accepting our Terms and Conditions. If you are registered with us, you can access our personalised services. Registered users also have the ability to change or delete the data entered during registration at any time. At any time, we will also provide you with information on the personal data about you that we have saved.

Legal basis
The data entered during registration are processed on the basis of the user’s consent (Art. 6 Para. 1 (a) GDPR). If the registration fulfils the obligations of a contract, whose contractual party is the data subject, or serves to implement pre-contractual measures, the additional legal basis for the data processing is Art. 6 Para. 1 (b) GDPR.

Recipients
Recipients of the data may be technical service providers, who work on the operation and maintenance of our website as the processor.

Retention period
Data are only processed in this context provided that the corresponding consent has been given. The data will be deleted thereafter, provided that no statutory retention obligations prohibit the deletion. To contact us in this regard, please use the contact information provided at the end of this privacy policy.

Mandatory or required provision
The provision of your personal data is voluntary, based solely on your consent. Without the provision of your personal data, we cannot give you access to our content and services.

Fashion Brands

circular.fashion offers personalised services to registered Fashion Brands. A scope of the services offered to Fashion Brands only can be found in our Terms and Conditions for Fashion Brands which need to be accepted upon registration. Personal data need to be submitted by Fashion Brands in the respective registration form and will be processed and collected by circular.fashion. The following data are required for us to grant access to Fashion Brands to our personalised services:

Company, profile and contact information

Personal name and last name
Contact phone number
Email address
Username and password
User group
Company name
Company address
Company website
Company department
Company VAT number
Commercial registry number
Number of employees
Billing address
Company Logo
Yearly turnover

Billing information:

Name
Company name
Billing address
Company VAT number


The legal basis for the processing of personal data as described in this paragraph is Art. 6 par. 1 lit. b GDPR.

circular.fashion will collect the following data via the Circular Material Library: Fashion Brands may provide data while registering their own materials on the Circular Material Library and potentially conducting Circular Material Check(s). Materials registered by a Fashion Brand are only visible to that Fashion Brand and not made public via the Circular Material Library. However there are additional services which would share defined data with third parties or publicly.Once a material has been used in a product that received a circularity.ID, a material cannot be deleted on the circular.fashion platform, in order to ensure lifelong access to product data for recycling partners and thereby recyclability of products. circular.fashion reserves the right to keep material information available to partners for as long as needed.

In order to make transparent which information is shared with which stakeholder group circular.fashion displays one or more icons at each relevant field of the upload form that represent specific stakeholder groups having access to the information entered in the field.

Data entered when registering a material to the My Material section of the Circular Material Library will only be visible to the fashion band that registered this material. This data includes information such as but not limited to material composition, colour way, dyeing method etc. (non-exhaustive list) and all fields will be market with the icon (t-shirt)

Data shared via circularity.ID publicly A material which has been registered on the Circular Material Library by a fashion brand, may be used by that fashion brand in their products which might receive a circularity.ID.. Specific material information will then be accessible to anyone scanning the circularity.ID. This data includes information such as but not limited to material composition, production country (non-exhaustive list) and data fields are labeled with the icon (public). For your reference, please check this example circularity.ID product site.

Data shared via circularity.ID and Sorting Software to sorting and recycling companies. Once a material was used in a garment that received a circularity.ID circular.fashion is authorized to save the material information provided, unlimited in time, and process the information as well as the result of the Circular Material Check with the Sorting Software. This data processed by sorting and recycling companies includes information such as but not limited to material composition, dye stuff, certificates etc. (non-exhaustive list) and respective data fields will be labeled with the icon (recycling). For some data points, sorting partners do not receive the actual data but a processed result of processed data in form of the Circular Material Check evaluation based on the provided data.

Material Supplier

circular.fashion offers personalised services to registered Material Suppliers. A scope of the services offered to Material Suppliers only can be found in our Terms and Conditions for Material Suppliers which need to be accepted upon registration. Personal data need to be submitted by Material Suppliers in the respective registration form and will be processed and collected by circular.fashion. The following data are required for us to grant access to Material Suppliers to our personalised services:

Company, profile and contact information

Personal name and last name
Contact phone number
Email address
Username and password
User group
Company name
Company address
Company website
Company department
Company VAT number
Commercial registry number
Number of employees
Billing address
Company Logo

Billing information:

Name
Company name
Billing address
Company VAT number

Registration information which are visible for registered users of the Circular Design Software:

Company name
Company website
Company address
Company email address
Phone number

circular.fashion handles the swatch service between Material Suppliers and Fashion Brands. If a Fashion Brand shows interest to place an order after purchasing the swatch, circular.fashion will establish the connection between the Fashion Brand and the Material Supplier or share the above mentioned contact information of the Material Supplier with the Fashion Brand.

The legal basis for the processing of personal data as described in this paragraph is Art. 6 par. 1 lit. b GDPR.

circular.fashion will collect and process the following data via the Circular Material Library and share with third parties for the purpose of the circular.fashion platform, i.e. Library users, in order to provide and offer a full range Circular Material Library within the scope of our services and contractual performance obligations“: Suppliers will provide data while registering materials on the Circular Material Library and potentially conducting Circular Material Check(s). In order to make transparent which information is shared with which stakeholder group circular.fashion displays one or more icons at each relevant field of the upload form that represent specific stakeholder groups having access to the information entered in the field. The user can un-publish their materials from the Circular Material Library at any time so it is not visible to users of the platform anymore. A material cannot be deleted on the circular.fashion platform once it has been published to the Circular Material Library, in order to ensure lifelong access to product data for recycling partners and thereby recyclability of products. circular.fashion reserves the right to keep material information available to partners for as long as needed.

Data shared via Circular Material Library and Swatch Service to registered users (e.g. Fashion Brands or designers) circular.fashion will publish specific data to the users of the Circular Material Library via the online tool as well as via the Swatch Service. This data includes information such as but not limited to material composition, colour way, dyeing method etc. (non-exhaustive list) and all fields will be market with the icon (t-shirt) By registering information of materials on the Circular Material Library a Material Supplier confirms that circular.fashion is allowed to share the uploaded information publicly with the users of the platform as well as to share specific information with recyclers for the purpose of the Circular Material Check. Furthermore circular.fashion is authorized to publish the results of the Circular Material Check on the Circular Material Library and the Swatch Service. Data shared via circularity.ID publicly A material which has been published to the Circular Material Library by a user, may be used by a Fashion Brand in their products which might receive a circularity.ID.. Specific material information will then be accessible to anyone scanning the circularity.ID of a product which uses the registered material. This data includes information such as but not limited to material composition, production country (non-exhaustive list) and data fields are be labeled with the icon (public). For your reference, please check this example circularity.ID product site.

Data shared via circularity.ID and Sorting Software to sorting and recycling companies Once a material was used in a garment that received a circularity.ID circular.fashion is authorized to save the material information provided, unlimited in time, and process the information as well as the result of the Circular Material Check with the Sorting Software. This data processed by sorting and recycling companies includes information such as but not limited to material composition, dye stuff, certificates etc. (non-exhaustive list) and respective data fields will be labeled with the icon (recycling). For some data points, sorting partners do not receive the actual data but a processed result of processed data in form of the Circular Material Check evaluation based on the provided data.

Newsletter

Type and purpose of the processing
Your data will be used exclusively to send you the newsletter you subscribed for via e-mail. We request your name so that we can address you personally in the newsletter and identify you as needed should you want to exercise your rights as a data subject.
To receive the newsletter, providing your e-mail address is sufficient. When you subscribe to our newsletter, the data you provide will be used exclusively for this purpose. Subscribers can also be notified by e-mail about circumstances that are relevant to the service or registration (such as changes to the newsletter offer or technical matters).
We need a valid e-mail address to complete your registration. In order to verify that a registration is actually made by the owner of an e-mail address, we utilise the ‘double opt-in’ procedure. To this end, we log the newsletter subscription request, when a confirmation e-mail is sent and the receipt of the requested reply. Additional data is not collected. The data will be used exclusively for sending the newsletter and will not be shared with third parties.

Legal basis
Based on your express consent (Article 6 (1) a GDPR), we will send you our newsletter on a regular basis or comparable information via e-mail to your specified e-mail address. The consent to save and use your personal data for the newsletter may be withdrawn at any time and remain in effect in the future. Every newsletter contains a corresponding link, and you can also unsubscribe on this website at any time or inform us of your cancellation via the contact option indicated at the end of this privacy policy.

Recipients
Recipients of the data may be the processors.

Retention period
Data are only processed in this context provided that the corresponding consent has been given. The data will be deleted thereafter.

Mandatory or required provision
The provision of your personal data is voluntary, based solely on your consent. Unfortunately, we cannot send you our newsletter without your consent.

Using Matomo

Type and purpose of the processing
This website uses Matomo (formerly Piwik), an open-source software for the statistical evaluation of visitors. The provider of the Matomo software is InnoCraft Ltd., 150 Willis St, 6011 Wellington, New Zealand. Matomo uses so-called ‘cookies’, which are text files that are stored on your computer and allow an analysis of your use of the website. The information generated by the cookie about your use of the website is stored on a server in: Germany The IP address is anonymised immediately after the processing and before it is saved. You have the option to prevent the installation of cookies by changing the settings of your browser software. Please note that with the corresponding setting, not all functions of this website may be available. You can decide whether a unique web analytics cookie may be stored in your browser in order to allow the operator of the website to collect and analyse various statistical data. You’ll find additional information on the privacy settings of the Matomo software at the following link: https://matomo.org/docs/privacy/.

Legal basis
The processing of the data occurs on the basis of our legitimate interest in accordance with Art.6 par.1 lit. f GDPR, or Art. 6 par. 1 lit. b if and to the extent that the processing is necessary for the performance of a contract to which our user is party or in order to take steps at the request of the data subject prior to entering into a contract.

Recipients
Recipients of the data may be the processors.

Retention period
The deletion of the data occurs as soon as they are no longer necessary for our recording-keeping purposes. In our case, this deletion occurs after a period of 12 months.

Mandatory or required provision
The provision of your personal data is voluntary, based solely on your consent. If you prevent access, this can lead to functional limitations on the website.

Revocation of consent
You can prevent the storage of cookies by a corresponding setting in your browser software; however, please note that in this case you may not be able to use all the functions of this website in their entirety.

Profiling
With the assistance of the tacking tool Matomo, the browsing behaviour of the website visitors can be evaluated and their respective interests can be analysed. For this analysis, we create a pseudonymous user profile.

SSL encryption

To protect the security of your data during transmission, we use state-of-the-art encryption methods (such as SSL) via HTTPS.

Online Courses on iSprings

During the registration for our Online courses, trainings and seminars personal data are transferred to iSprings which are required to perform our contractual obligations to you on the e-learning platform being hosted by iSprings. iSprings is processing personal data on our behalf on the basis of a Data Processing Agreement, which reflects the legal situation under applicable European Law, such as the General Data Protection Regulation GDPR according to iSprings Data Protection Agreement.

Revision of our privacy policy

We reserve the right to amend this privacy policy so that it always complies with current legal requirements or to implement changes to our services in the privacy policy, e.g. when introducing new services. Your next visit will be subject to the new privacy policy.

Questions for the data protection officer

If you have any questions pertaining to data protection, please send us an e-mail at circular.fashion UG (haftungsbeschränkt)
team@circular.fashion
Phone +49 30 40 3679170
Skalitzer Strasse 97, 10997 Berlin, Germany
The privacy policy was created via the activeMind AG Privacy Policy Generator (Version: 2018-09-24).