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Privacy Policy

 DIGITAL AFRICA DATA PROTECTION INFORMATION

This Data Protection Information provides information on the processing of your personal data whenever you visit this website of PUMA Austria (hereinafter “PUMA”, “we” or “us”, unless otherwise specified) and when purchasing goods from said website.


1. Scope, data controller, data protection officer and definitions 

1.1. Scope of this Data Protection Information

This Data Protection Information applies to the use of the website of PUMA, including the online shop and any measures connected for the execution and rescission of an online purchase, the creation of a customer account, the newsletter dispatch, further informative emails and customer services, and for our marketing activities on third-party websites. Data processing on websites of other companies within the PUMA Group are not covered by this Data Protection Information.


1.2. The Controller for the processing of your personal data

Depending on the purposes of processing identified in Section 2 of the Data Protection Information, your personal data may be processed by PUMA or by Global-e who operates the checkout page of the online shop and is the merchant of record:

1.2.1.

Austria PUMA Dassler GmbH (PUMA)

 

Siezenheimer Straße 39, A 5020 Salzburg, Austria

 

Email: privacy-dfa@puma.com                                   

   

1.2.2.

E COMMERCE GLOBALE MIDDLE EAST FZCO (Global-E)

 

Address: BCB2 511-SD 59, Fifth Floor, Business Cluster - Building 2, Dubai CommerCity, UAE

 

Email: DPO@Global-e.com      

   


1.3. Definitions

This Data Protection Information is based on the following terms under data protection law, which we have defined to facilitate understanding. 

  • GDPR means Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).
  • Recipient means a natural person 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 enquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by the public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing; 

Examples of possible recipients: Banks/payment providers, logistic firms and shipping service providers and IT services providers; for more information please refer to Section 4).

  • PUMA Group means all enterprises that are affiliated with PUMA pursuant to Section 15 Aktiengesetz [German Stock Corporation Act]. 
  • Personal data means any information relating to an identified or identifiable natural person (“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 or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. 

Examples of personal data: Name, contact details, bank or credit card details.

  • Controller means the natural person 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. 

For the data processing activities described in this Data Protection Information, the Controllers are PUMA and/or Global-E, unless otherwise specified (Section 1.2.). 

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


2. Purposes and legal bases of our processing of your personal data 

2..1. Processing of your data when you visit our websites

If you visit our websites in order to find out about products and services without registering for a customer account, purchasing products in our online shop or otherwise actively transferring information to us (purely for informational purposes), we process your personal data for the following purposes and by virtue of the following legal bases: 

 

2..2. Provision of websites and IT security

PUMA processes your personal data that are technically necessary to allow us to provide our websites to you and to guarantee stability and security when you visit our websites. This includes the following personal data: 

  • IP address
  • type and version of browser
  • operating system and platform 
  • the complete Uniform Resource Locator (URL)

These personal data will be stored for security purposes in server log files, which will automatically be deleted after 7 days.

This data processing is necessary for the purpose of enabling you to use our websites (Legal basis: Art. 6 (1) sentence 1, lit. b GDPR) as well as for the purposes of our legitimate interest to guarantee IT security (Legal basis: Art. 6 (1) sentence 1, lit. f GDPR). 


2..3. Provision of localised websites

PUMA processes your personal data that are technically necessary to allow us to provide you with a localised version of the websites, in particular with regard to the language. 

This data processing is necessary for the purpose of our legitimate interest to adapt our website to your needs (Legal basis: Art. 6 (1) sentence 1, lit. f GDPR).


2.2.4. Website Analytics

Use of cookies 

On our website PUMA uses cookies. Cookies are small text files that are stored in the browsers of your end devices whenever you visit our websites. Through cookies, your actions and settings on our websites can be tracked, stored and recognized for the duration of the browser session or even after this. In addition to this, cookies and their respective cookie IDs allow your browser to be recognised. For example, after leaving the website, you can reconstruct the content of your shopping card or be shown the last seen products.

For more information about the use of cookies on our websites, the cookie categories and for individual settings please refer to our Cookies Settings.

2.2.3.1 Google Tag Manager

On our websites, we use the Google Tag Manager, a service of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland ("Google").

The Google Tag Manager enables PUMA to use so-called website tags via a web-based user interface provided to us by Google.

Website tags are "measurement codes and associated code fragments" that can communicate with Tag Manager servers and be configured through a web-based user interface, Google Tag Manager.

Google Tag Manager also allows us to resolve other website tags that may also collect data.

In order to provide the service, we set a cookie if you have given consent to the activation of the cookie (Art. 6 para. 1, lit. a GDPR).

When using the Google Tag Manager, we use the so called "server-side tagging" variant by Google. Further information can be found in the section on server-side tagging in our Privacy Policy. Your IP address is not transmitted to Google LLC, which is based in the USA.

In the event that your personal data is transferred to Google LLC in the U.S., Google LLC has taken appropriate measures to ensure compliance with the level of data protection requirements applicable in the European Union or the European Economic Area (e.g. certification in the EU-U.S. Data Privacy Framework adopted by the EU Commission; conclusion of standard data protection clauses).

You can find more information about Google Tag Manager on the following Google web pages:

2.2.3.2. Google Analytics

We use Google Analytics on our websites, a web analysis service der Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland („Google“).

Google Analytics uses cookies that allow an analysis to be made on the usage of our websites.

When using the Google Analytics, we use the so called "server-side tagging" variant by Google. Further information can be found in the section on server-side tagging in our Privacy Policy. Your IP address is not transmitted to Google LLC, based in the USA.

When using Google Analytics, we may also use so-called UTM tags. UTM tags are specially created links that we include, for example in email newsletters, for example, which send us information about the call with an activated Google Analytics cookie. This allows us to collect information about our advertising campaigns.

On behalf of PUMA, Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity, analyzing the effectiveness of our digital advertising and improving its customization, and providing other services relating to website activity and internet usage to PUMA. You can find more information on terms of use and data protection at

https://policies.google.com/terms

https://policies.google.com/privacy

The processing of your personal data is based on consent pursuant Art. 6 para. 1 s. 1, lit. a GDPR.

You can give your consent to Google Analytics in our cookie banner. You can revoke this consent at any time with effect for the future by deactivating Google Analytics in our Cookies Settings.

If you do not give us your consent to analyze your data using Google Analytics, we will analyze the usage of our website without tracking your personal data with Google Consent Mode. You can find more information about Google Consent Mode in the corresponding passage of this Privacy Policy.

The analysis of the UTM tags described above is also prevented by deactivating the Google Analytics cookie.

If you consent to the processing of your personal data for analysis purposes by Google Analytics and if you have consented to the use of Google Ads, it is possible that we may also use the data generated by Google Analytics in connection with Google Ads. Further information and the purposes of data processing by Google Ads can be found in the corresponding section on Google Ads.

2.2.3.3. Google Consent Mode

  • If you do not give us your consent to analyze your data using Google Analytics, we will not track your personal data.
  • In these cases, we use the Google Consent Mode of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Google Consent Mode allows us to carry out an analysis using so-called modeling, which takes place without the use of cookies and without processing your personal data.
  • To carry out the so-called modeling, we process the following data without personal reference to your visit to our website: Function-related data (timestamp, user agent, referrer URL), aggregated data (Boolean information on the status of consent, random number when building each separate page, references to information on the ad click in the URL in the user's navigation history of the previous or current page and information on the consent platform used).
  • Further information on Google Consent Mode can be found at:
  • https://support.google.com/google-ads/answer/10000067?hl=en

2.2.3.4. Google Adds

To make you aware of our attractive offers by advertisements through our retargeting providers, we use the "Google Ads" service of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland ("Google").

These advertisements are published by so-called "AdServers". For this purpose, we use "AdServer cookies", which help us to measure certain parameters for success, such as the display of ads or actuation of the links. Furthermore, this helps us to show you individual recommendations on our website by analyzing your behavior on our website, like viewed products and the content of your shopping cart. PUMA is a "Google Ads customer" in this respect.

When you access our websites via an advertisement distributed by Google, Google Ads stores a cookie in your browser and on your end device, if you have activated the cookie. These cookies enable the recognition of your web browser. Google Ads cookies do not serve the purpose of identifying you personally and usually lose their validity after 30 days.

Usually, the Google Ads cookie stores the following information on your end device and transfers it to Google: Unique cookie ID, number of ad impressions per placement (frequency analysis), opt-out information (if the user has chosen the opt-out option), and last impression for post-view conversions. Each Google Ads customer is assigned an individual cookie based on the information already contained in the cookie. Cookies are not tracked via our websites.

When using the Google Ads, we use the so called "server-side tagging" variant by Google. Further information can be found in the section on server-side tagging in our Privacy Policy. Your IP address is not transmitted to Google LLC, which is based in the USA.

In the event that your personal data is transferred to Google LLC in the U.S., Google LLC has taken appropriate measures to ensure compliance with the level of data protection requirements applicable in the European Union or the European Economic Area (e.g. certification in the EU-U.S. Data Privacy Framework adopted by the EU Commission; conclusion of standard data protection clauses).

If the Google Ads cookie is activated and you visit our website by clicking on an advertisement, Google and PUMA can determine that you have reached our website via the advertisement.

After transferring the data stored in the cookie through Google Server-Side-Tagging we only receive statistically processed evaluations of the respective advertising measures from Google. We do not receive detailed information about the user through this data. We cannot identify you as a user through this data. This data allows us to determine whether and which of our advertising measures are effective. We have no influence on the further use of the data and the scope of the data that Google collects through Google Ads.

According to our knowledge, Google can assign the visit to our websites by clicking on a corresponding advertising measure to your user account with Google, provided that you have such a user account.

The processing of your personal data is based on your consent pursuant to Art. 6 para. 1 s. 1, lit. a GDPR, which you grant by setting or saving the cookies. You can revoke this consent at any time with effect for the future by deactivating the corresponding cookie in our Cookies Settings. This activates a so-called opt-out cookie, which prevents the processing of your personal data during future visits to our websites. If you deactivate the cookie, it is possible that you will only be able to use the functions of our website to a limited extent.

For more information on the processing of your personal data, please refer to the following link: https://policies.google.com/privacy

Information on Google's use of data can be found at the following link: https://services.google.com/sitestats/en .html

You can object to this data processing for individual recommendations by clicking on the following opt-out link: https://adssettings.google.com

If you consent to the processing of your personal data for the purpose of evaluating certain parameters to measure the success of our advertising measures through Google Ads and if you have consented to the use of Google Analytics, it is possible that we may also use the data generated by Google Analytics in connection with Google Ads. Further information and the purposes of data processing by Google Analytics can be found in the corresponding section on Google Analytics.

2.2.3.5. Google Enhanced Conversions for the Web

In order to better align our Google Ads ad impressions of potential customers and actual conversions of prospects to customers on our websites, we use Google Enhanced Conversions for the Web from Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland ("Google").

This is done with the help of so-called conversion tracking tags via Google Tag Manager. Tags are "measurement codes and associated code fragments" that can communicate with the Tag Manager servers and can be configured via a web-based user interface, the Google Tag Manager. A cookie is not set for this purpose.

If you, as a customer, go from one of our advertisements to our websites and order a product there, we receive your data directly, including your email address.

Your email address is used by us as a so-called identifier and is recorded in the conversion tracking tags, hashed and transmitted to Google in this hashed form. Google uses this data to associate your actions and purchases on our website with your Google account, provided that you have registered an account with Google and logged into it when you clicked on an ad. We have no influence on the further use of the data and the scope of the data that Google collects.

We use this information to improve our measurement of the conversion of prospects to customers on our websites. This is done by tracking sales and actions that take place on our websites, as well as Google's attribution of the submitted data.

The processing of your personal data is based on consent pursuant Art. 6 para. 1 s. 1, lit. a GDPR.

You can give your consent to Google Enhanced Conversions in our Cookies Settings. You can revoke this consent at any time with effect for the future by deactivating Google Enhanced Conversions in our cookie banner.

More information about Google Enhanced Conversions for the Web can be found at the following link : https://support.google.com/google-ads/answer/9888656?hl=en

General information on data protection at Google can be found at the following link: https://policies.google.com/privacy

2.2.3.6. Google server-side tagging

In order to better protect your personal data when using Google products, we use Google's so-called server-side tagging. This means that PUMA interposes its own server between the collection of your personal data and the transmission to Google's servers. This intermediate step ensures that Google only receives the personal data that is actually absolutely necessary for the proper execution of the specific purpose of the corresponding Google products. Your personal data will only be transmitted to Google in at least a pseudonymized, if possible in an anonymized state, e.g. in hashed form.

We use Google server-side tagging as part of the use of the following Google services: Google Analytics, Google Ads, Google Tag Manager.

2.2.3.7. Meta Conversions API & Meta Pixel

We use the so-called "Meta Pixel" and the so-called "Meta Conversions API" of Meta Platforms Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland ("Meta") on our website.

By using Meta Pixel, we are able to determine target groups and audiences for our advertisements (so-called "Meta Ads") in Meta's social networks. The purpose of this is to display the advertisements we publish only to those users of Meta's social networks who have an interest in our products or in content determined on the basis of the websites they visit.

We transfer the information obtained by the Meta pixel (so-called "Meta Custom Audiences") to Meta.

In this context, we also use the so-called "Conversions API" from Meta. This allows us, in conjunction with the Meta pixel, to track your actions after you have seen or clicked on an advertisement on Meta's social networks.

The use of these services helps us to measure certain parameters to determine the success of our advertisements, for example in the form of the display of advertisements or the activation of links.

If you have given us your consent to activate the Meta Conversions Cookie, you also have the option to give us your consent to use other analysis methods for marketing purposes- These analysis methods are carried out with the help of so-called conversion tracking tags via Google Tag Manager. Tags are "measurement codes and associated code fragments" that can communicate with the Tag Manager servers and can be configured via a web-based user interface, the Google Tag Manager. A cookie is not set for this purpose.

If you, as a customer, go from one of our advertisements to our websites and order a product there, we receive your data directly, including your email address.

Your email address is used by us as a so-called identifier and is recorded in the conversion tracking tags, hashed and transmitted to Meta in this hashed form. Meta uses this data to associate your actions and purchases on our website with your account of Meta's social networks, provided that you have registered an account with Meta's social networks and logged into it when you clicked on an ad. We have no influence on the further use of the data and the scope of the data that Meta collects.

When the Meta pixel is used, your browser automatically establishes a direct connection with the Meta server. This means that your IP address is transmitted to Meta in hashed form.

In the event that your personal data is transferred to Meta Platforms Inc. in the U.S., Meta Platforms Inc. has taken appropriate measures to ensure compliance with the level of data protection requirements applicable in the European Union or the European Economic Area (e.g. certification in the EU-U.S. Data Privacy Framework adopted by the EU Commission; conclusion of standard data protection clauses).

We have no influence on the further use of the data and the scope of the data that Meta collects and processes. According to our knowledge, Meta can assign the visit to our websites by clicking on a corresponding advertising measure to your user account with Meta, provided that you have such a user account. Meta also receives information about you clicking one of our advertisements or about you having visited our website. Meta can use this information for the purpose of market research and adjusting their Meta Websites.

If you have a registered account with any of Meta's social networks, you can set the types of advertisements that will be displayed to you within the Social Networks from Meta by going to the page set up by Meta and following the instructions on the settings for usage-based advertising. The settings are platform-independent, i.e. they are applied to all devices, such as desktop computers or mobile devices.

Please note that, even if you do not have a registered account with any of Meta's social networks or have not logged in, there is a possibility that the provider will find out and store your IP address and other identifying features.

Further information can be found in Meta's privacy policy: https://www.facebook.com/privacy/policy/?entry_point=data_policy_redirect&entry=0

The processing of your personal data is based on consent pursuant Art. 6 (1) lit. a GDPR. You can give your consent to “Meta Pixel” and “Meta Conversions API” in our cookie banner. You can revoke this consent at any time with effect for the future by deactivating these tools in our cookie banner.

2.2.3.8. Emarsys

PUMA uses Emarsys for personalization, analytics, automation and email campaigns (sending newsletters). Emarsys works through cookies and tracking pixels which help us to create newsletters and tailored advertisements. If you give your consent to receive our newsletter and have fully completed the double opt-in process to verify your email address accordingly your personal data will be collected by Emarsys and combined into a [pseudonymized] user profile which can be assigned to your email address. When you visit our website, the data collected by Emarsys can also be merged into a [pseudonymized] user profile if you had given your consent to receive our newsletters at one of our retail stores. Your email address will be pseudonymized by us. If you have given your consent for receiving our newsletter we will process your following data: if you have opened our newsletter, what you have clicked on, when and how much time have you been surfing on our website, what products and categories have you been looking at, what have you purchased on our web shop and when, from what category at what cost and have you completed the check-out process.

The data protection guidelines of Emarsys can be found here:

This data processing (evaluation of the newsletter and the measurement of success) is based on our legitimate interests - subject to your given consent - to ensure the secure and user-friendly operation of our newsletter system and thus serves both our business interests and your expectations to improve our website, products and services (Legal basis: Art. 6 (1) sentence 1, lit. f GDPR).


To process data on your user behaviour like watched products, content of shopping cart etc. in order to show you individual recommendations on our websites based on this data. For further details on the processing of data by Google Ads please refer to Google’s privacy policy under the following link:

This data processing is necessary for the purpose of our legitimate interest to create a better user experience by tailored recommendations (Legal basis: Art. 6 (1) sentence 1, lit. f GDPR).

Individual recommendations Opt-out:

You can object to this data processing by clicking on the following opt-out link:


Other retargeting providers

For details on data processing by our other retargeting providers, please refer to the corresponding privacy policies:

  • Meta Ads: https://www.facebook.com/about/privacy

Data processing is partly based on consent in accordance with Art. 6 para. 1 s. 1, lit. a GDPR by activating a cookie. You can revoke this consent at any time for the future by deactivating the corresponding cookie in our Cookies Settings. If you deactivate the cookie, you may only be able to use the functions of our website to a limited extent.

Furthermore, we may have a legitimate interest in advertising our products individually and efficiently on the Internet (Legal basis: Art. 6 para. 1 s. 1, lit. f GDPR).

Objection to retargeting/display advertising

You can object to data processing on our websites for the purpose of display advertising/retargeting on third-party websites at any time by clicking on the link(s) of our provider(s) listed below:

2.2.6. Affiliate Marketing/Conversion Tracking

We have also embedded cookies and similar tracking technologies from our affiliate (network) partners into our websites. With these tools our affiliate (network) partners can recognize whether you came from one of our affiliate publishers (i.e. third party websites that advertise PUMA products) and then track if you perform a certain predefined “conversion” action (e.g. newsletter subscription or purchase of a product) on our websites in consequence.

The processing of your personal data is based on consent pursuant Art. 6 para. 1 s. 1, lit. a GDPR.

We use the following affiliate network partners:

CJ - Epsilon International UK Ltd, 1st Floor 2 Television Centre, 101 Wood Lane, London, England, W12 7FR

You can give your consent to CJ in our cookie banner. You can revoke this consent at any time with effect for the future by deactivating the corresponding cookie in our Cookies Settings


2.2.7. Customer care 

Depending on the subject matter of your request, PUMA and/or Global-e will rely on your personal data that has been stored within the scope of other data processing activities in the systems (e.g. data that you have provided during a purchase). If and to the extent that this is necessary to answer your query, PUMA and/or Global-e will also collect data from external sources (e.g. query with a shipping service provider as part of shipment tracking or an investigation request). 

In context of requests concerning a (pre)contractual relationship with you, this data processing is necessary for the performance of a contract (provision of a customer service) with you (Legal basis: Art. 6 (1) sentence 1, lit. b GDPR). If you wish to exercise your rights with respect to PUMA and/or Global-e, the correspondent data processing is necessary for compliance with a legal obligation (Legal basis: Art. 6 (1) sentence 1, lit. c GDPR). If you would like to receive information or complain about the products and services, the respective data processing is necessary for the purpose of PUMA’s and/or Global-e’s legitimate interest to respond to your information request/complaint (Legal basis: Art. 6 (1) sentence 1, lit. f GDPR).


2.3. Email marketing

2.3.1. Email newsletter dispatch to subscribers

If you have subscribed to our email newsletter either through the sign-up feed on our website or by checking the tick-box on the check-out page to receive newsletters from PUMA and have passed the “double opt-in” procedure we will send you from time-to-time newsletters to inform you about our products, services and promotions. 

This data processing is based on your consent (Legal basis: Art. 6 (1) sentence 1, lit. a GDPR).

Withdrawal of consent:

You can withdraw your consent and unsubscribe from our newsletter at any time by sending an email with your unsubscribe request to service-dfa@puma.com and/or by clicking on the unsubscribe link which is contained in every newsletter.


2.3.2. Personalization of direct marketing emails to existing customers

If you are a customer, PUMA may personalize our direct marketing mails send to you based on your preference/interest profile derived from data of your previous purchase(s) from the last two years.

This data processing is necessary for the purpose of our legitimate interest to tailor our direct marketing emails to your preferences and interests and thus make our email marketing efforts more efficient (Legal basis: Art. 6 (1) sentence 1, lit. f GDPR).

Objection to our newsletter/direct marketing targeting

You can object to this processing of your purchase data for targeting of our newsletter/direct marketing emails to custom audiences at any time by sending an email with your unsubscribe request to service-dfa@puma.com and/or by clicking on the unsubscribe link which is contained in every direct marketing email. In this case, you would then not receive any more newsletters from us. 


2.4. Registration and setting up a customer account     

When you visit our websites, you can create a customer account. The registration for a customer account requires you to provide personal data which is processed by PUMA. Mandatory fields are marked accordingly in the input form. 

This data processing is necessary for the performance of a contract (provision of a customer account) with you (Legal basis: Art. 6 (1) sentence 1, lit. b GDPR). 


2.5. Data processing in the case of orders in the online shop

In addition, Puma and/or Global-e processes your personal data in connection with the purchase of goods in our online shop.

2.5.1. Purchase and payment of goods in the online shop 

Global-E processes your personal data (i.a. contact details, shipping and payment information) if you purchase goods in the online shop. If you purchase goods for another person (third party), Global-e processes the personal data of the third party provided by you (name and any contact details) for the dispatch of the goods to the third party. Please ensure that the third party has been sufficiently informed by you about the processing of their data, and that you are authorised to provide such data. 

This data processing is necessary for the performance of a contract with you (Legal basis: Art. 6 (1) sentence 1, lit. b GDPR). This data processing is performed at Global-e’s sole responsibility. Further information about Global-e’s processing activities can be found in their privacy notice.


2.5.2. Shopping cart abandonment emails 

If you have started an ordering process using your customer account, but have not concluded it, PUMA will send you a reminder email to the email address stored in the customer account, regarding the purchasing process initiated by you. 

This data processing is necessary for the purpose of our legitimate interest to remind you of any purchasing processes that you have not yet completed (Legal basis: Art. 6 (1) sentence 1, lit. f GDPR).

Objection to shopping cart abandonment emails:

You can object to this processing of personal data and unsubscribe from our shopping cart abandonment emails at any time by sending an email with your unsubscribe request to service-dfa@puma.com and/or by clicking on the unsubscribe link which is contained in every shopping cart abandonment email.

2.5.3. Fraud and credit check

Before concluding the purchase contract, Global-e carries out a fraud and credit check. This is done to enable Global-e to offer you a choice of different payment methods and at the same time to protect against the default of payment of the invoice.

In addition to that Global-e will check, based on your device on pre-defined rules, if the order should be categorised as being suspected of fraud. If there is any suspicion of fraud, they will additionally carry out an individual check on the order. The result of this manual fraud check can either be positive, which would lead to the order being approved. If, however, the suspicion of fraud remains, Global-e may decide to cancel the order, depending on the particular case.

This data processing necessary for the purpose of Global-e’s legitimate interest to avoid default of payment and fraud (Legal basis: Art. 6 (1) sentence 1, lit. f GDPR). This data processing is performed at Global-e’s sole responsibility. Further information about Global-e’s processing activities can be found in their privacy notice.


2.5.4. Cancellation of purchase

In any case of cancellation of the purchase (e.g. withdrawal of contract) Global-E will process your personal data for returning the goods and refunding the purchase price.

This data processing is necessary for the performance of a contract with you (Legal basis: Art. 6 (1) sentence 1, lit. b GDPR) and/or for compliance with a legal obligation (Legal basis: Art. 6 (1) sentence 1, lit. b GDPR lit. c GDPR). This data processing is performed at Global-e’s sole responsibility. Further information about Global-e’s processing activities can be found in their privacy notice.


2.5.5. Dunning process, collection and enforcement and/or defence of legal claims

In the case of outstanding amounts owed to us, Global-E will advise you accordingly by email, SMS, letter or by phone, and under certain circumstances, will send you a dunning letter. If and to the extent that you still fail to make the payment, Global-e will initiate a credit collection procedure. 

In the case of a legal dispute with you, Global-e will process your personal data to enforce and/or defend their rights. If and to the extent necessary for the legal dispute, Global-e will thereby rely also on data from other sources (e.g. public registers).

This data processing is necessary for the performance of a contract with you (Legal basis: Art. 6 (1) sentence 1, lit. b GDPR) as well as for the purpose of Global-e’s legitimate interest in preventing the abuse of their services and in establishment and exercise of legal claims (Legal basis: Art. 6 (1) sentence 1, lit. f GDPR). This data processing is performed at Global-e’s sole responsibility. Further information about Global-e’s processing activities can be found in their privacy notice.


2.6. Other processing 

2.6.1. Performance of internal audits 

Within the scope of audits within the PUMA Group, both at home and abroad, your personal data may be processed. During this process, we rely also on data from other sources, depending on the case (e.g. credit agencies). 

Your data may, under certain circumstances, also be appropriately processed in order to identify and rectify misconduct within the enterprise, and to implement compliance programmes and compliance measures.

This data processing is necessary for compliance with our legal obligations (e.g. under the Stock Company Act) (Legal basis: Art. 6 (1), sentence 1, lit. c GDPR) and/or for the purpose of our legitimate interest to check the processes and efficiency in the PUMA Group, to rectify misconduct and cases of fraud, to enforce and/or defend our rights, as the case may be, and to uncover any criminal offences, (Legal basis: Art. 6 (1) sentence 1, lit. f GDPR).


2.6.2. Issuing of analyses 

On the basis of your data, which we process the meaning of Section 2 of this Data Protection Information, PUMA may issue analyses. These serve as a basis for our business decisions, to improve our products and services, to adapt to the needs of our customers and to carry out marketing activities. The analyses issued on this basis no longer have any personal reference, which means it is no long-er possible to trace them back to you.

This data processing is necessary for the purpose of our legitimate interest to improve the products and services we offer and carry out marketing activities (Legal basis: Art. 6 (1) sentence 1, lit. f GDPR). 

2.6.3. Prize Competitions & Raffles

PUMA offers you the chance to participate in prize competitions and raffles on this Website, as well as in our stores, on social media like Instagram, Facebook, TikTok, with our Affiliate Partners, in Newsletters, or similar.

Your personal data will be processed with your participation. In all our prize competitions and raffles, you only need to provide us with the data that we require to perform the raffle and to notify you of your win. Typically, this is your email address, but additional data might be required based on the applicable terms and conditions of certain raffles.

If the raffle is about winning PUMA Sportswear (clothes and shoes), we ask for your name, your clothing or shoe size and your gender in addition to your email address. In order to be able to collect the prize from us, we may also ask you to inform us of the store of your choice, where you can pick up your prize by giving your name. If the prize is sent by post, which can be in case you can win tickets, vouchers or other non-cash prizes, we need your home address in addition to your name. In some cases, we might additionally ask for your age to ensure that you can legally participate in the raffle based on the applicable terms and conditions. You will find further information on all this in the terms and conditions that apply.

The data required by us to perform the raffle under the applicable terms and conditions are highlighted as mandatory fields. Unfortunately, participation in the raffle is not possible without entering your data in the marked mandatory fields. Other, unmarked fields, however, are optional and you decide yourself whether you want to share further data with us. Participation in the raffle does not depend of your optional data and has no effect on the performance of the raffle.

In the event of your participation, we process the data you provide to us in the raffle solely for the purpose of performing the raffle and notifying the winner. The same applies if you provide us with data based on terms and conditions for raffles on social media (Instagram, Facebook, Twitter, ...), e.g. by uploading a photo or posting articles, linking hashtags, using handles or commenting on our campaigns. The applicable terms and conditions may stipulate that we publish your name and address on our social media platforms (Instagram, Facebook, Twitter, ...) to announce you as a winner and your prize.

Please note, that your data will be deleted after the raffle.

Within the scope of our raffles, you also have the opportunity to give us your consent to the use of your data for advertising. Your consent to advertising has no effect on your participation in the raffle. If you give us your consent to receive advertising, such as newsletters per email, usually by ticking a checkbox, we will process your data, especially your email address, also to send you offers and information about our products by email. You can withdraw your consent at any time. Further information on data processing when receiving our newsletter can be found under the section “Newsletter”.

We process your personal data based on your consent in accordance with Art. 6 sec. 1 lit. a GDPR and, where applicable, to fulfil a legal obligation in accordance with Art. 6 sec. 1 lit c GDPR. Your data will not be passed on to third parties. In individual cases we are supported by external service providers with whom we have concluded a corresponding agreement to ensure the security of the processed data.

Of course, you can exercise the rights to which you are entitled under data protection law against us at any time. You will find more detailed information on this under the section “Your Rights”.


3. Retention and erasure of your personal data 

PUMA keeps your personal data for as long and to the extent required for the purposes named in this Data Protection Information (Section 2). 

As soon as the data for the purposes named in Section 2 is no longer required, we keep your personal data for the length of time, during which you can assert claims against us or we can assert claims against you .

In addition to this, we store your personal data for as long and to the extent we are obliged to do so by law. Corresponding obligations of proof and retention can be found, inter alia, in local commercial or tax codes or money laundering acts. The retention periods may accordingly last up to ten years. 

Further information about Global-e’s retention practices can be found in their privacy notice.

 
4. Transfer of personal data and the categories of recipients

Besides Global-e, your personal data may be transferred/disclosed to the following categories of recipients:

  • Other companies within the PUMA Group within the scope of a group-internal, collaborative process. Such data processing, where applicable, is necessary for the purpose of our legitimate interest to run our administration activities efficiently and collaboratively, and to improve our products and services (Legal basis: Art. 6 (1) sentence 1, lit. f GDPR). 
  • IT Service providers who prepare the platforms, databases and tools for our products and services (e.g. our website,  the dispatch of newsletters and informative emails), issue analyses on user habits on our websites, carry out marketing campaigns, and process your personal data on our behalf.

In connection with the use of Google Analytics and Google Ads, including tags and cookies, your personal data may be transferred to the USA.

  • For the analysis of your behaviour on our website, we transfer your personal data to specialised service providers. Data is transferred to third party countries. In
  • In order to offer you localised versions of our websites, we transfer your personal data to a third-party service provider in the USA
  • For the delivery of products (including notifications about the delivery status) we transfer your personal data to the fulfilment and shipping service providers engaged by us. The transfer of your personal data is based on the performances of a contract with you (Legal basis: Art. 6 (1) sentence 1, lit. b GDPR).
  • In the case of legal disputes, we transfer your data to the competent court and, if you have engaged a lawyer, to the latter, in order to conduct the legal dispute. This transfer of personal data is necessary for compliance with a legal obligation (Legal basis: Art. 6 (1) sentence 1, lit. c GDPR) and/or for the purpose of our legitimate interest in the establishment and exercise of legal claims (Legal basis: Art. 6 (1) sentence 1, lit. f GDPR).
  • In addition to this, we only transfer your personal data if we are legally obliged to forward such data (e.g. to the police authorities within the scope of criminal investigations or to the data protection supervisory authorities). This transfer of personal data is necessary for compliance with a legal obligation (Legal basis: Art. 6 (1) sentence 1, lit. c GDPR).Anchor
     

We ensure that suitable safeguards (e.g., certification in the EU-U.S. Data Privacy Framework adopted by the EU Commission, conclusion of applicable EU Standard Contractual Clauses and, if necessary, additional measures) for adequate data protection are in place, if your personal data is disclosed to any recipients mentioned above, which are established outside the EU/EEA.

Further information about Global-e’s recipients can be found in their privacy notice.

5. Right to object to data processing based on legitimate interests

Where we process your personal data within the meaning of Section 2 based on our legitimate interest and you want further information about the balancing of interests carried out by us, please contact us via the respective contact details in Section 1.

Notwithstanding the specific possibilities to object to data processing described in Section 2 (e.g. provided opt-out or unsubscribe links), you have the right to object at any time to the processing of your personal data on the basis of our legitimate interests pursuant to Art. 6 (1) sentence 1, lit. f GDPR on grounds relating to your particular situation by sending an email to the respective contact details in Section 1. We will then no longer process your data for this/these purpose(s) unless our legitimate interests in processing overweight or the processing serves to establish, exercise or defend legal claims. 

If you object to the processing of your data, we will process any collected personal data in this context in order to respond to your request. This data processing is necessary for compliance with a legal obligation (Legal basis: Art. 6 (1) sentence 1, lit. c GDPR).

Further information about Global-e’s handling of data subject rights can be found in their privacy notice.

 
6. Right to withdraw consent 

If you have given us your consent for the processing of your personal data, you can withdraw this consent at any time. The withdrawal of your consent is effective for the future and shall not affect the lawfulness of processing based on consent before its withdrawal. 
Unless specifically regulated in Section 2, please send your withdrawal of consent to the respective contact details in Section 1.

If you withdraw your consent, we process your personal data collected in this connection to answer your inquiry. This data processing is necessary for compliance with a legal obligation (Legal basis: Art. 6 (1) sentence 1, lit. c GDPR). 

Further information about Global-e’s handling of data subject rights can be found in their privacy notice.

 
7. Your other data protection rights 

In accordance with the GDPR, you may demand at any time that we:

  • provide you with information on your personal data that we process (Art. 15 GDPR),
  • rectify (Art. 16 GDPR),
  • erase (Art. 17 GDPR), 
  • restrict (Art. 18 GDPR) and/or 
  • export (Art. 20 GDPR)

your personal data stored on our systems.

Please send your request, stating at least your first and last name by email  to the respective contact details in Section 1.

If you exercise these rights against us or Global-e, the respective controller will process your personal data in order to respond to your request. This data processing is necessary for compliance with a legal obligation (Legal basis: Art. 6 (1) sentence 1, lit. c GDPR).

Irrespective of your abovementioned rights, you can lodge a complaint with a data protection supervisory authority, if you are of the opinion that the processing of your personal data by us or Global-e violates the GDPR (Art. 77 GDPR).

Further information about Global-e’s handling of data subject rights can be found in their privacy notice.

 
8. Changes to this Data Protection Information

The provisions of this Data Protection Information, including the referenced Cookie Information, shall apply in the version in force at the time the online shop is used. 

We reserve the right to supplement and modify the content of this Data Protection Information. The updated Data Protection Information applies from the time, in which it was published on our websites. In case of substantive or material changes to the Data Protection Information, especially changes that affect the processing of your personal data already collected by us, we will inform you in advance (e.g. by email).