Privacy Policy FOURSOURCE

(Version 3.0, updated 19 February 2019)

FOURSOURCE Group GmbH, Torstraße 149, 10119 Berlin (hereinafter “FOURSOURCE”) operates the domain www.foursource.com ( the “Website”) and thereunder, provides a members-only platform addressed to manufacturers, brands, retailers and other buyers of fashion and lifestyle products (the “Platform”).

FOURSOURCE protects the privacy of all users and strictly complies with all applicable data protection provisions, including the European General Data Protection Regulation (Datenschutzgrundverordnung) (“GDPR”) and the German Telemedia Act (Telemediengesetz).

The following privacy policy informs about the use and processing of personal data of users visiting the Website without registration or log-in. If you are a registered user of the Platform, you may view our privacy policy for registered users after logging in at www.foursource.com.

1) Processing of data in case of communication towards us

  • Due to our statutory obligation under Art. 5 para. 3 of the German Telemedia Act (Telemediengesetz), the Website contains information which makes it possible to contact us quickly in electronic form and to directly communicate with us. If you decide to contact us, for example via e-mail or via the contact form, the personal data you transmitted is automatically stored in order to process your request. The legal basis for such processing and storage is Art. 6 para. 1, lit. cGDPR. The data you communicated will not be transferred to third parties. It will only be stored as long as we need to deal with your request (e.g. to answer your question).

2) Webtracking

(a) Use of Log Files in Case of Errors 

  • When you visit the Website, FOURSOURCE collects the following usage data upon a crash or other malfunction of the Website and sends them to an internal logfile: anonymized IP address, browser information, computer information, network information. FOURSOURCE uses such data only to detect or to eliminate errors which prevent the Website from operating properly.

(b) Use of Cookies 

  • FOURSOURCE also collects information on the use of the Website by using the browser Cookies from the third party provider Google. FOURSOURCE only uses this Cookie type. Browser Cookies are small text files stored on the users data storage medium, which save the specific settings and data exchange via the browser. A Cookie typically contains the name of the domain from which the Cookie has come, information on the age of the Cookie and alphanumeric identifiers. Cookies help FOURSOURCE to identify the user’s device and to immediately make available possible preferences. When you access the Website, a Cookie is transmitted to your hard disk of the computer or the mobile device. Cookies help FOURSOURCE to improve the Website and offer better services by making the services more user-friendly. The Cookies used by FOURSOURCE may save the following data on the use of the Website:
    • ∙ device’s IP address (captured and stored in an anonymized format)
    • ∙ device screen resolution
    • ∙ device type (unique device identifiers), operating system, and browser type
    • ∙ geographic location
    • ∙ preferred language used to display the Website
    • ∙ mouse events (movements, location and clicks)
    • ∙ keypresses
    • ∙ referring URL and domain
    • ∙ pages visited
    • ∙ geographic location (country only)
    • ∙ date and time when Website pages were accessed.
  • There will be no reference to the name of an individual user, but a reference to an identification number pertaining to the Cookie (“Cookie-ID”). In case the user does not consent to the use of browser Cookies, the user can change the browser settings, so that a storage of Cookies will not be accepted. However the Website may not function properly and/or some features may not be available in that case.
    In more detail:
    Google Analytics
    FOURSOURCE uses Google Analytics, a web analytics service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”). We use Google Analytics in the form of the “universal analytics” function provided by Google, i.e. the analysis of data from your use of our Website is based on a pseudonymous user ID and pseudonymous profile which extends to various devices you use (so-called “cross-device tracking”). The information generated by Google Analytic’s Cookie about your use of the Website (including your IP address) will first be stored on a server of Google within the European Union or the European Economic Area and will then be transmitted to and stored by Google on servers in the United States. Please note that on this Website, Google Analytics code is supplemented by “anonymizeIp” to ensure an anonymized collection of IP addresses (so called IP-masking), Google therefore anonymizes the last octet of the IP address. Only in exceptional cases, the full IP address is sent to and shortened by Google servers in the USA.
    Such data transmissions are allowed under the EU commission’s decision about the adoption of the EU-US data protection framework “Privacy Shield” (https://www.privacyshield.gov/welcome). Google is certified under the EU-US Privacy Shield Framework. On behalf of the Website provider Google will use this information for the purpose of evaluating your use of the Website, compiling reports on Website activity for Website operators and providing other services relating to Website activity and internet usage to the Website provider. Google will not associate your IP address with any other data held by Google. You may refuse the use of Cookies by selecting the appropriate settings on your browser. However, please note that if you do this, you may not be able to use the full functionality of this Website. Furthermore you can prevent Google’s collection and use of data (Cookies and IP address) by downloading and installing the browser plug-in available under https://tools.google.com/dlpage/gaoptout?hl=en-GB. You can refuse the use of Google Analytics by clicking on the following link. An opt-out Cookie will be set on the computer, which prevents the future collection of your data when visiting this website: https://tools.google.com/dlpage/gaoptout?hl=en. Further information concerning the terms and conditions of use and data privacy can be found at http://www.google.com/analytics/terms/gb.html or at https://www.google.de/intl/en_uk/policies/.Google automatically deletes all information collected within 14 months.

(c) Use of GoogleAds and Conversion Tracking without Sign-Up

  • We also use Google’s online marketing tool “GoogleAds”. Via GoogleAds, we place advertisements (“ads”) within Google’s “Display Network” (i.e. such ads are shown above your Google search results when you use Google, or on websites of third parties which are partners within Google’s advertisement network). Such ads are personalized, i.e. shown to users who are more likely to be interested in them. This includes personalization for remarketing purposes, i.e. ads are more likely shown to you if you have formerly been interested in online offers similar to our products. To this end, when you visit any website within the Google Display Network, Google integrates a code on such websites (so called “web beacons”). With their help, a Cookie or a similar technology will be placed on your device. At the same time, we receive an individual “conversion Cookie”. With this conversion Cookie, Google prepares conversion statistics for us, enabling us to see how many users have clicked on an ad we placed and how many of these users then performed an activity which we defined beforehand (such as clicking on certain subpages on our Website, e.g. signing up, signing up for a newsletter, viewing promotional videos, following our social media channels, or contacting us via our website through chat or e-mail). To enable this, we equip the subpages which we want to count as a conversion activity with a “conversion tag” provided by Google. We do not see your identity when using Google’s conversion tracking (Certain information may, however, be stored if you sign-up to create an Account or successfully create an Account. For more information on this, please see our “Privacy Policy for Registered Users”, which will be provided to you before you sign up.) Data relevant for displaying such ads and subsequent conversion tracking is processed pseudonymously by Google and its partners, i.e. Google does not store or process data such as your name or email address, unless you have expressly permitted Google to do so. For more information about Google’s use of Cookies in advertising, please visit https://policies.google.com/technologies/ads?hl=en. You can manage your ad settings within the Google services on your Google account (https://adssettings.google.com/authenticated?hl=en). Also, you can manage cookies in the settings of the web browser you use.
    Data relevant for displaying such ads and subsequent conversion tracking is processed pseudonymously by Google and its partners, i.e. Google does not store or process data such as your name or email address, unless you have expressly permitted Google to do so. For more information about Google’s use of Cookies in advertising, please visit https://policies.google.com/technologies/ads?hl=en. You can manage your ad settings within the Google services on your Google account (https://adssettings.google.com/authenticated?hl=en). Also, you can manage cookies in the settings of the web browser you use.
    We use GoogleAds and its personalization to show ads only to users who are potentially interested in them. Conversion tracking allows us to find out which ads users found interesting and therefore, to improve them.

(d) Legal basis

  • The legal basis for webtracking and subsequent processing of personal data under this Section 2 are our legitimate interests according to Art. 6 para. 1, lit. f) GDPR. 

3) Your Rights under the GDPR

  • The aforementioned processing of data results from your use of the Website or opting-in for a newsletter or contacting us. You are neither contractually or statutory obliged to provide these data to FOURSOURCE. Under the EU General Data Protection Regulation, you are entitled to
    • ∙ withdraw your consent to process your data (e.g. the consent to receive newsletters) at any time (for this, simply contact us as described below); and
    • ∙ request which data we process and have stored. However, in cases where we only stored anonymized use profiles (such as the ones generated by the use of webtracking), we cannot match such profiles with your individual details such as your name or address. Therefore, we can only fulfill your request if you grant us the information necessary to conduct such matching. We will inform you if fulfillment of your information request is only possible with such further information;
    • ∙ request – under the statutory required preconditions – the completion, correction or deletion of your data; and
    • ∙ receive the necessary data in a structured, common and machine readable format as far as processing of your data is based on consent (e.g. the consent to receive newsletters); and
    • ∙ object to any processing of data which is based on Art.6 para. 1 lit. e) or f) GDPR (e.g. in the case of webtracking), as far as the requirements of Art. 21 para. 1 of the General Data Protection Regulation are met (i.e. on grounds relating to your particular situation).

4) Right to Complaint

  • You have a right to file a complaint with a data protection authority. The data protection authority competent for FOURSOURCE is the Commissioner for Data Protection in Berlin (https://www.datenschutz-berlin.de/)
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