Privacy

1. Controller

Responsible for the data processing described in this privacy policy is NEUNOI Sneaker GmbH, Bergstrasse 47, 8032 Zurich, Switzerland.

Email: info@neunoi.ch · Phone: +41 79 546 46 12 · VAT ID: CHE-213.385.354 · Commercial register no.: CH-020.4.087.395-7

Data protection enquiries can be sent to info@neunoi.ch.

2. Scope and legal bases

This privacy policy applies to the website neunoi.ch, the online shop operated through it, the NEUNOI Sneaker Subscription, newsletters, take-back and repair processes as well as other contacts with NEUNOI.

We process personal data in accordance with Swiss data protection law, in particular the Federal Act on Data Protection (FADP). Where the General Data Protection Regulation of the European Union (GDPR) applies in an individual case, we additionally take its requirements into account.

Where the GDPR applies, we base data processing in particular on the performance of a contract or pre-contractual measures, legal obligations, our legitimate interests or a consent that has been given. Consent can be withdrawn at any time with effect for the future.

3. What personal data we process

Depending on how our offering is used, we may process in particular the following personal data:

– Master data, e.g. name, billing and delivery address, country and language;

– Contact data, e.g. email address, telephone number as well as messages and correspondence;

– Order and contract data, e.g. products ordered, size, colourway, order value, delivery status, returns, vouchers, credit and complaints;

– Subscription data, e.g. term, shoe exchanges, returns, condition of the shoes provided as well as information on loss or damage;

– Payment and transaction data, e.g. chosen payment method, payment status, transaction reference and refunds; we generally do not receive full card information;

– Take-back and repair data, e.g. condition, photos, repair needs, work carried out, successor size and benefits granted;

– Communication data, e.g. enquiries by email, contact form, telephone, Instagram or WhatsApp;

– Newsletter data, e.g. sign-up, proof of consent, opens, clicks and unsubscribes;

– Technical and usage data, e.g. IP address, browser, device, operating system, referrer, pages accessed, interactions, cart actions, timestamps and cookie identifiers;

– Voluntarily submitted content, e.g. feedback, photos, drawings or stories.

As a rule we collect data directly from the data subjects. In addition, data may originate from Shopify, payment service providers, shipping companies, advertising and analytics platforms or other service providers involved.

4. Purposes of processing

We process personal data in particular for the following purposes:

– operation, security and technical development of the website and the online shop;

– presentation of products, size information, availability and the shopping cart;

– handling of orders, payments, shipping, returns and refunds;

– operation of the NEUNOI Sneaker Subscription, in particular size changes, returns and management of the rented shoes;

– organisation of take-back, inspection, cleaning, repair, refurbishment and passing on of used shoes;

– customer service, answering enquiries, handling complaints and warranty cases;

– sending the newsletter and other subscribed information;

– reach measurement, analysis of user behaviour and improvement of the website, range, communication and customer experience;

– advertising and measuring the success of campaigns, in particular on Instagram and Facebook;

– prevention and investigation of misuse, fraud, security incidents and technical faults;

– compliance with legal obligations, accounting, tax and corporate documentation as well as the enforcement and defence of claims.

5. Visiting the website and server log data

When our website is accessed, technically necessary data is processed automatically. This may include IP address, date and time, content accessed, volume of data transferred, referrer, browser, operating system, device information and error messages.

This data is needed to provide the website, detect attacks and misuse, fix errors and ensure the stability and security of the service. Log data is retained only for as long as necessary for these purposes or to comply with legal obligations.

6. Cookies and similar technologies

Our website uses cookies, pixels, local storage technologies and comparable technical means. These are small pieces of information that can be stored on a device or read when a page is accessed.

6.1 Necessary technologies enable in particular the shopping cart, checkout, language settings, security, fraud prevention and the storage of privacy settings. Without these functions the online shop cannot be operated reliably.

6.2 Analytics and marketing technologies help us understand how the website is used, which campaigns work and which content is relevant to visitors. Where legally required, such technologies are only activated after corresponding consent.

6.3 Visitors can make their selection via the cookie or privacy banner used on the website and change it later. In addition, cookies can be deleted or blocked in the browser settings. Blocking certain technologies may restrict individual functions of the website.

7. Hosting and infrastructure with Vercel

Our website is hosted with Vercel, a service of Vercel, Inc., USA, which operates a globally distributed infrastructure (content delivery and edge network). Vercel provides the website and serves content from a geographically nearby data centre.

When the website is accessed, Vercel, as our processor, processes the technically necessary connection and server log data, in particular IP address, date and time, content accessed, referrer as well as device and browser information. This serves the provision, security, stability and performance of the website.

In doing so, data may also be processed outside Switzerland, in particular in the USA. Vercel’s privacy notices apply in addition.

8. Shopify and operation of the online shop

Our online shop is operated with Shopify. For customers from Switzerland and the European area, primary processing is carried out by Shopify International Limited, Ireland. Shopify may engage affiliated companies and sub-processors in further countries in order to provide its services.

Shopify processes in particular master data, contact data, order information, payment status, technical usage data and cookie identifiers in order to provide the storefront, shopping cart, checkout, security, payment processing and further shop functions.

Shopify may also process certain data under its own responsibility, for example for security, fraud prevention, compliance with its own legal obligations or improvement of its services. Further information is available in Shopify’s privacy notices.

9. Orders, delivery, returns, take-back and repairs

8.1 Order and contract: when an order is placed, we process the information required to conclude and perform the contract. This includes in particular contact, delivery, order and payment information.

8.2 Shipping: for delivery we pass the necessary data such as name, delivery address, email address, telephone number and shipment information to the commissioned shipping or logistics company. There, the data may be used for delivery, shipment tracking, notification and handling of delivery problems.

8.3 Returns and complaints: for returns and complaints we process information about the order, the reason for return, condition, communication, photos and the refund. This serves inspection, processing and quality assurance.

8.4 Take-back system and repair: for the voluntary return of shoes that have already been worn, we process in particular contact data, shoe size, condition, photos, repair needs, repair history, vouchers or credit granted and information about passing the shoes on. Where repair, cleaning, logistics or social enterprises are involved, they receive only the data they need for their task.

8.5 NEUNOI Sneaker Subscription: for the subscription we additionally process information on term, payments, size changes, returns, the condition of the rented shoes, loss, damage and termination. This data is necessary to administer the subscription, provide suitable shoes and ensure their return.

10. Payment processing

At checkout, the payment methods displayed at the relevant time are available, for example credit card, TWINT or Apple Pay. Payment processing takes place via Shopify and the selected payment service provider.

Payment service providers process the data required to authorise and carry out the payment under their own or joint responsibility. This may include name, billing address, transaction amount, payment instrument, device and fraud prevention data. As a rule, NEUNOI receives only information on payment status and the transaction, but not complete card or account details.

The privacy notices of the payment service provider selected at checkout apply in addition.

11. Contacting us and communication

When people contact us by email, telephone, contact form, Instagram, Facebook, WhatsApp or by other means, we process the transmitted contact and content data in order to answer the enquiry and for any follow-up steps.

Where communication takes place via external platforms, their privacy provisions apply in addition. Sensitive information should not be transmitted via social networks or messengers. We may continue contract-relevant or particularly important enquiries by email to ensure reliable handling.

12. Newsletter with Brevo

To send our newsletter we use Brevo, a service of Brevo GmbH in Berlin, Germany. In doing so, in particular email address, name, language, time of sign-up, proof of consent, opens, clicks, technical delivery data and unsubscribes may be processed.

Signing up is voluntary. Where used, the double opt-in procedure serves to confirm the sign-up and prevent misuse. The newsletter can be unsubscribed at any time via the unsubscribe link in each message or by email to info@neunoi.ch.

Based on opens and clicks, Brevo can evaluate statistically which content is used. This evaluation helps us make newsletters clearer and more relevant. Where consent is required for this, the evaluation takes place on that basis.

13. Google Analytics 4

We may use Google Analytics 4, an analytics service provided by Google. For users in the European area, Google Ireland Limited, Ireland, is regularly the contact; data may also be processed by Google companies in other countries.

Google Analytics helps us understand how visitors find and use the website. This may involve, among other things, pages accessed, events, approximate region, device and browser information, campaign parameters, cookie or device identifiers and interactions in the shop. According to Google, for users from Switzerland, the EU and the United Kingdom, Google Analytics does not store individual IP addresses, but uses the IP address briefly to derive an approximate region.

Where legally required, Google Analytics is only activated after consent via the privacy banner. Consent can be withdrawn at any time via the cookie settings. The specific retention period depends on the settings we have configured in Google Analytics and on Google’s specifications.

We take care not to knowingly transmit directly identifying details such as names, email addresses or complete payment information to Google Analytics.

14. Meta Pixel and advertising on Instagram and Facebook

We may use the Meta Pixel and the associated advertising and measurement functions provided by Meta. For users in the European area, Meta Platforms Ireland Limited, Ireland, is regularly the provider.

The Meta Pixel can record that a person has visited our website or performed certain actions, for example viewed a product page, created a shopping cart or completed an order. Among other things, URL, timestamp, browser and device information, cookie identifiers, IP address, campaign information and event data may be processed.

Depending on the technical configuration, data may be used to attribute website activity to Meta accounts, measure ads, build audiences and display relevant advertising. In doing so, Meta may combine data with information from Facebook, Instagram and other Meta services. As a rule, NEUNOI receives aggregated evaluations and no complete Meta profiles of individual persons.

Where legally required, Meta technologies are only activated after consent via the privacy banner. Consent can be withdrawn at any time. Anyone who has a Meta account can additionally manage their advertising settings directly with Meta.

15. Product analytics and error tracking with PostHog

We use PostHog, a product analytics tool provided by PostHog, Inc. For our service, the data is processed on servers in the European Union (EU region, eu.i.posthog.com).

PostHog helps us understand how the shop is used. This may involve in particular pages accessed, events and interactions (e.g. product views, cart actions, start of checkout, take-back processes), device and browser information, approximate region, IP address as well as pseudonymous identifiers (distinct ID, session ID). For troubleshooting, we additionally record technical errors that occur automatically (exceptions). Some of these events are also transmitted server-side.

We take care not to transmit directly identifying details such as names, email addresses or complete payment information to PostHog.

Where legally required, PostHog is only activated after consent via the privacy banner. Consent can be withdrawn at any time via the cookie settings. PostHog’s privacy notices apply in addition.

16. Map display with Mapbox

On the “Production” page we display an interactive map of our production partners. For this we use Mapbox GL, a service of Mapbox, Inc., USA.

When the map is loaded, the browser retrieves map tiles, fonts and symbols from Mapbox and may in doing so transmit technical usage data such as the IP address, device and browser information and details about map usage to Mapbox. Mapbox may process this data under its own responsibility, in particular to provide and secure the map service.

In doing so, data may also be processed in the USA. Mapbox’s privacy notices apply in addition.

17. Videos with Vimeo

On individual pages we embed videos via the player provided by Vimeo (Vimeo.com, Inc., USA). When a page containing a video is accessed, the browser establishes a connection to Vimeo’s servers, in the course of which in particular the IP address as well as technical device and browser information may be transmitted to Vimeo.

We embed the videos with the “Do Not Track” (dnt) parameter so that, according to Vimeo, these playbacks are not evaluated for Vimeo’s own tracking and advertising purposes. In doing so, data may also be processed in the USA. Vimeo’s privacy notices apply in addition.

18. Social media presences

NEUNOI maintains presences on social networks, in particular Instagram and Facebook. When people visit our profiles, comment on posts, send messages or interact with content, both NEUNOI and the respective platform process data.

Platform providers may also evaluate usage behaviour for their own analytics and advertising purposes. The scope and duration of this processing are largely determined by the platform operators. Their privacy provisions and account settings apply.

19. Recipients and processors

We may disclose personal data, to the extent necessary, to the following categories of recipients:

– shop, hosting, IT, security and support service providers;

– payment service providers, banks and fraud prevention providers;

– shipping, logistics, returns, cleaning and repair partners;

– newsletter, analytics, advertising and communication providers;

– accounting, fiduciary services, insurers, legal and other professional advisors;

– authorities, courts or other bodies, where a legal obligation exists or this is necessary to enforce rights.

Service providers receive only the data they need to fulfil their task. Where they process data on our behalf, we contractually oblige them to maintain appropriate data protection and confidentiality.

20. Processing abroad

Some of the providers we use, and their subcontractors, process personal data outside Switzerland, in particular in the European Economic Area, the United Kingdom, Canada or the USA. Foreign authorities may request access to data under the conditions applicable there.

We only disclose personal data to countries recognised as providing adequate data protection, or we use suitable safeguards such as recognised standard contractual clauses and additional protective measures. Where a provider is certified under a data protection framework recognised for Switzerland, this may also serve as a basis for transfer. In the exceptional cases provided for by law, disclosure may take place in particular to perform a contract, on the basis of consent or to enforce rights.

21. Retention period

We retain personal data only for as long as it is needed for the respective purpose, consent exists, a legitimate interest applies or statutory retention obligations apply.

Order, contract, payment and accounting records are generally retained for the period prescribed by law. Communication, repair and subscription data is stored for as long as necessary for support, processing, quality assurance and any claims. Newsletter data is retained until unsubscription and thereafter only as far as necessary as suppression or evidence information.

Data may be retained longer where claims are threatened or exist, a security incident is being investigated or a legal obligation requires it. Thereafter, data is deleted or anonymised.

22. Data security

We take appropriate technical and organisational measures to protect personal data against unauthorised access, loss, misuse, alteration or disclosure. Depending on the risk, these include in particular access restrictions, encrypted transmission, secure accounts, updates, backups and carefully selected service providers.

Nevertheless, transmitting data over the internet or storing it in digital systems can never be guaranteed to be entirely free of risk. Customers should keep access credentials confidential and report suspicious activity to us as quickly as possible.

23. Children’s data

Our products are aimed at children, but the online shop and the conclusion of contracts are aimed at adults of legal age or adults with parental responsibility. We do not intend to collect personal data directly from children without their parents’ knowledge.

Photos, drawings, stories, names or other content created by children are accepted only voluntarily and with the consent of a person with parental responsibility. Publication does not happen automatically but only on the basis of suitable consent. Parents can withdraw such consent with effect for the future.

24. Automated decisions and profiling

We currently do not make any decisions based solely on automated processing that produce legal effects concerning a person or similarly significantly affect them.

Analytics and advertising services may derive user groups, interests or probabilities in order to measure campaigns or serve advertising. This may qualify as profiling. Where necessary, such functions are used only with consent and can be deactivated via the privacy or cookie settings.

25. Rights of data subjects

Within the framework of applicable data protection law, data subjects can in particular assert the following rights:

– information about whether and which personal data we process;

– rectification of inaccurate or incomplete data;

– deletion or restriction of processing, provided no overriding reasons or obligations prevent it;

– release or transfer of certain data in a common electronic format, provided the statutory requirements are met;

– objection to certain data processing;

– withdrawal of consent with effect for the future;

– complaint to a competent data protection supervisory authority.

A message to info@neunoi.ch is sufficient to exercise these rights. We may request suitable proof of identity so that data is not disclosed to unauthorised persons. Statutory restrictions and retention obligations remain reserved.

In Switzerland, a complaint can be addressed to the Federal Data Protection and Information Commissioner (FDPIC).

26. Changes to this privacy policy

We may adapt this privacy policy if our offerings, the services we use, our processes or legal requirements change. The version published on neunoi.ch at the relevant time applies. In the event of material changes, we will provide notice in a suitable form.

27. Contact

Questions about data protection, requests for information or other concerns can be addressed to: NEUNOI Sneaker GmbH, Bergstrasse 47, 8032 Zurich, Switzerland; info@neunoi.ch; +41 79 546 46 12.