Zalando
Data protection statement

We process your data in the necessary scope to fulfil contracts and to provide and execute further services requested by you, as described in this Data Protection Declaration. The purposes of the necessary data processing therefore depend on the purpose of the contract agreed with you (including our General Terms and Conditions and any service-specific terms and conditions or terms of use) or services requested by you. The most important purposes are:

• The provision, personalisation and needs-based design of our services such as the Zalando shop and Zalon (including their respective websites, apps and cross-device and cross-platform functions).
• The provision of local services, e.g. in Zalando Outlet Stores and at events and trade fairs.
• The execution of customer programmes such as Zalando Outlet Card and Zalando Plus.
• The execution of purchase agreements and customer service including dispatch and payment processing, claim management as well as the processing of returns, complaints and warranty claims.
• The provision of messages, reports, newsletters and other direct communication, insofar as these are an integral component of our contractual services or the services requested by you.

• The guarantee of the general security, operability and stability of our service including defence from attacks.
• Non-promotional communication with you on technical, security-related and contractually relevant subjects (e.g. fraud warnings, account blocking or contractual changes).
• The mediation of contracts via our trading and sales platform, perhaps within the framework of the Zalando partner programme or Zalando Wardrobe.
• The issuing, redemption, delivery of Zalando vouchers.
• The execution of campaigns and competitions.

Legal basis:

Insofar as the purpose relates to the execution of a contract agreed with you or the provision of a service requested by you, the legal basis is Article 6 (1) b GDPR. Otherwise, the legal basis is Article 6 (1) f GDPR, whereby we may use your personal data for the above purposes if we deem it necessary to do so for our legitimate interests.

We process your data for the provision of comfortable and useful services which correspond as well as possible to your needs and interests. Because the Zalando shop’s range encompasses hundreds of thousands of products and thousands of brands, it is necessary that we present our content and offers in a needs-based manner so that you can find products you are actually interested in. This requires a user-specific evaluation of the relevance of products and content.

To personalise shopping in the Zalando shop we use device and access data which we collect for usage analysis. Alongside this, we also use device and access data which we receive from advertising partners while you visit the Zalando shop. If you are logged in with your customer account while visiting the Zalando shop, we also use profile data, interest data and shopping data to personalise your shopping experience. We refer to this form of shopping personalisation as on-site optimisation. Only such shopping personalisation allows us to present you with suitable search results, product suggestions, style recommendations and other content corresponding to your actual interests. Without such shopping personalisation, as carried out today by many online shops as standard, your search for relevant products would be less convenient and more protracted and the utility of our range for you would be lower. Shopping personalisation does not, of course, prevent you from accessing all content. It does, however, allow you to see content which is more relevant to you more quickly.

Legal basis:

The legal basis for the processing of your data for shopping personalisation within the framework of personalised services is Article 6 (1) b GDPR. The legal basis for the processing of your data within the framework of on-site optimisation is Article 6 (1) f GDPR, whereby our legitimate interests are in the above purposes.

We process the data collected on our customers for scientific research in the areas relevant to Zalando. This includes in particular the research areas of machine learning, artificial intelligence, natural language processing and deep learning. Research at Zalando concentrates on solutions to real, everyday online shopping problems and is meant to serve the improvement and development of the existing services range. In this way, for example, we can develop apps which can suggest products targeted to your interests and needs and recognise styles and assign products which correspond to your actual interests.

In doing this, of course, we observe recognised scientific data protection standards. This also means that we only process your data in summarised, anonymised or pseudonymised form for research purposes, for example by replacing all identifiable data such as your name with other values.

Research at Zalando includes the following purposes:

• The development of machine learning procedures allowing estimates, prognoses and analysis of the needs and interests of our users.
• The development of technical solutions for real customer problems which our specialist departments and fashion manufacturers encounter in day-to-day business (e.g. difficulties in finding suitable products, reducing the probability of bad buys, sizing).
• The development of technical solutions for optimising business and logistics processes.
• The development of technical solutions facilitating the improvement and development of shopping personalisation and fraud prevention.
• The registration of patents and publication of specialist articles.
• Participation in research communities and academic cooperation partners.

Legal basis:

The legal basis for the processing of your data within the framework of the research purposes described above is Article 6 (1) f GDPR, whereby our legitimate interests are in the above purposes.

Prevention of fraud

In order to combat the risk of data security breaches, data pertaining to users of our services is encrypted in transmission. This applies both to ordering and to registering for a customer account. For this we use the coding system SSL (Secure Socket Layer). Encryption prevents third parties from viewing the data. To provide additional protection from external attacks, we rely on special security technologies which constantly check our systems and identify and report anomalies. We also use technical and organisational measures to secure our systems against loss, destruction, unauthorised access or distribution of customer data by unauthorised persons. In this manner we wish to keep the risk of unauthorised access as low as possible, because protecting your data is our top priority. However, we - like other companies - cannot guarantee absolute protection.

We also use technical and manual procedures for fraud prevention in order to protect us and our users from misuse of data, especially by fraudulent orders. To this end, Zalando Payments GmbH summarises and evaluates your device and access data (including IP address, identifiers, user behaviour), shopping data and payment details (including address and other creditworthiness data from external credit agencies) as well as the change history of your profile information (e.g. when your delivery address was last changed) under a pseudonym when executing an order. The record is also compared with your previous usage and order habits. We also compare it to general records from all Zalando orders (also from other Zalando Group companies) involving confirmed or suspected fraudulent actions. This comparison allows us to identify fraud patterns and to prevent fraud and identity theft by comparing patterns.

Following registration for a customer account, Zalando Payments GmbH transmits your name and your addresses as given in the profile to external credit agencies. This serves to ensure that you are actually registered and can be reached at the disclosed addresses. Typical indicators which - usually in combination - may increase the probability of attempted fraud include:

• Your delivery address was changed shortly before the submission of the order and/or is in a region with increased risk of fraud.
• Your order is particularly large and/or includes products which are subject to particularly high demand at present and/or are carried out at an unusual time for your region (e.g. at night).
• The payment methods invoice or direct debit are used for the order.
• There were suspicious login attempts on your account before the order was submitted, the pattern of which suggests automation.
• Your customer account is used from a suspicious IP address.
• Your customer account is used by an unknown or suspicious device.

If our security system suspects attempted fraud or an increased risk of fraud, the relevant procedure will be forwarded to the Zalando fraud team for manual investigation. Appropriate preventative measures will be taken in view of the risk of fraud (e.g. temporary blocking of the customer account or restriction of payment methods offered).

Legal basis:

If your data is processed to prevent fraud at your expense, the legal basis is Article 6 (1) b GDPR. This processing of your data otherwise occurs on the basis of Article 6 (1) f GDPR, based on our legitimate interest and that of other users in the identification and prevention of fraud and clarification of criminal offences.

Choice of payment methods

Before we show you the payment methods available for a purchase, Zalando Payments GmbH will carry out a risk assessment. Your previously collected purchase data, payment details, creditworthiness data, data on your previous payment behaviour as well as your profile information (such as surname, first name, delivery and billing address, email address, date of birth) will be used to carry out the risk assessment. The assessment and evaluation will be carried out automatically using statistically justified estimates of the default risk in relation to the payment methods we offer. Within the framework of the risk assessment, Zalando Payments GmbH also transmits your data to external credit agencies to receive general information from these on the evaluation of the payment-specific default risks (e.g. on whether your address is plausible and up-to-date) as well as, in individual cases, creditworthiness data, perhaps on open invoices and circumstances directly resulting in a risk of payment default (e.g. insolvency, deferral due to inability to pay). Which specific creditworthiness data is taken into account in the course of the risk assessment may vary from country to country.

The default risk is assessed separately for each payment method in the form of an estimate. If the risk assessment yields a positive result, we can offer all the payment methods we generally offer. Otherwise, we will only offer you particular payment methods. Factors which may influence the availability of a payment method include:

• The combination of name and address could not be found. This may result from typing errors, moves, marriage or a change of district.
• You have given a delivery address, packing station or company address differing from the billing address.
• There are still open claims against you.
• There have been payment disruptions with particular payment methods in the past.

The risk assessment will not mean that you are not offered any payment method. If you are not in agreement with the payment methods offered, you can inform us of this in writing by letter or email at privacy_policy@zalando.co.uk. We will then check the decision again, taking your viewpoint into account.

Legal basis:

If you have given consent to the processing of your data as described above for the choice of payment methods, the legal basis is Article 6 (1) a GDPR (Consent). Otherwise, the legal basis is Article 6 (1) f GDPR, based on our legitimate interest in avoiding default risks.

Credit check

In addition to the risk assessment Zalando Payments GmbH, processes your data before showing you the payment methods we make available for a purchase from us, in the course of an automated credit check. This check serves to prevent payment defaults and to ensure our security, as it allows us to recognise attempted fraud and other offences.

Along with data already in Zalando Payments GmbH’s possession, creditworthiness data from external credit agencies in the form of score values is also used. Score values are statistically justified estimates of the future risk of a person defaulting and are represented as a numerical value, such as a percentage. To this end, Zalando Payments GmbH transmits on our behalf the personal data required for a credit check (generally your first and last name, your address and if necessary your date of birth) to the external agency. Address data may also be taken into account when calculating your score. The credit agency uses the data transmitted by us to correspondingly assess your creditworthiness on the basis of mathematical-statistical procedures.

Depending on the result of the credit check, i.e. whether it is positive or negative, we will show you appropriate payment methods which you can use to continue and complete your purchase.

If you are not in agreement with this, you can inform us of this in writing or by email at privacy_policy@zalando.co.uk. We will then check the decision again, taking your viewpoint into account.

Legal basis:

The legal basis for the credit check described above is Article 6 (1) b GDPR, because it is necessary for the execution of necessary pre-contractual measures. This processing of your data otherwise occurs on the basis of Article 6 (1) f GDPR, based on our legitimate interest and that of other users in the avoidance of payment defaults, the identification and prevention of fraud and the clarification of criminal offences.

We use your data, also within the framework of data analysis, for advertising and market research, in particular for the following purposes:

• Classification into various target and user groups within the framework of market research (user segmentation).
• Findings on various target groups and their respective usage habits and shopping interests.
• The production of findings on demography, interests, our users’ shopping and usage habits as well as the marketing on these findings within the framework of advertising services provided to third parties.
• The early identification of trends in the areas of fashion and online shopping.
• The execution of advertising to existing customers.
• The execution of direct marketing, e.g. in the form of newsletters.
• The planning, execution and success monitoring of advertising corresponding to the interests of the target groups being addressed (personalised advertising).
• Findings as to how our services are used (usage analysis).
• The marketing of the above findings within the framework of advertising services for advertising customers.

Depending on the purpose, we use the data we have stored for data analysis. For example, we use summarised (aggregated), statistical, depersonalised (anonymised) profile information or data which can only be assigned to persons via further intermediate steps (pseudonymised profile information) as well as shopping and device and access data in order to understand and analyse purchasing processes using data analysis. This gives us anonymous or pseudonymised findings on our users’ general usage behaviour.

We process your data on the basis of balancing of interests to protect our legitimate interests or those of third parties (such as advertising partners or dealers which participate in Zalando’s partner programme). Zalando’s legitimate interest or that of third parties in data processing derives from the relevant purposes and is, unless otherwise indicated, of a competitive and economic nature.

Legal basis:

If data processing for the above purposes occurs with your consent, the legal basis is Article 6 (1) a GDPR (consent). This data processing data otherwise occurs on the basis of Article 6 (1) f GDPR, whereby the legitimate interests are for the above purposes.

We use your data for product and technology development including the development and improvement of personalised services. In doing this we use aggregated, pseudonymised or anonymised data and machine learning algorithms, perhaps from our research, which facilitate estimates, prognoses and analysis in the interests of our users. In this way, for example, we can develop apps which can suggest products targeted to your interests and needs and recognise styles and assign products which correspond to your actual interests. Data is processed in relation to product and technology development particularly for the following purposes:

• The development and improvement of personalised services and technologies for data analysis, advertising and personalised online shopping.
• The development of technologies and concepts to improve IT security, prevent fraud and improve data protection e.g. by pseudonymisation, encryption and anonymisation technologies.
• The development and testing of software solutions for the optimisation of necessary business and logistics processes.

Legal basis:

The legal basis for the processing of your data for product and technology development purposes is Article 6 (1) f GDPR, whereby our legitimate interests are in the above purposes.

We transmit and process your data where necessary for administrative and logistical processes and to optimise business processes within Zalando Group in order to design these in a more efficient and legally secure way and to fulfil our contractual and legal obligations (e.g. retention obligations under commercial and tax law). Many systems and technologies are shared within Zalando Group. This allows us to offer a more economical, secure, unified and personalised service. Therefore, various companies within Zalando Group have access to your data in so far as this is necessary for the fulfilment of the purposes named in this Data Protection Declaration.

Data processing for business management and business optimisation also includes, for example, the following purposes:

• The execution and improvement of customer service.
• The prevention and clarification of criminal offences.
• Guaranteeing the security and operability of our IT systems.

Legal basis:

The legal basis for the processing of your data for business management and optimisation is Article 6 (1) f GDPR, whereby our legitimate interests are in the above purposes. Where we process your data on the basis of legal specifications, e.g. retention obligations and money laundering tests under tax law, the legal basis is Article 6 (1) c GDPR.

If you have given us your consent for the processing of personal data, your consent is the primary basis of our data processing. Which of your data we process on the basis of your consent depends on the purpose of your consent. Typical purposes include:

• Subscription to a newsletter.
• Participation in surveys and market research studies.
• The processing of particularly sensitive data, containing e.g. your political opinions, religious or ideological convictions or state of health.
• The recording of telephone conversations which you have e.g. with our hotline.
• The transmission of your data to third parties or to a country outside the European Union.
• The execution of a credit check (if it is not necessary for contractual fulfilment or precontractual measures).

If data protection law allows it, we can use your data for new purposes such as carrying out data analyses and developing our services and content without your consent. It is a prerequisite for this that these new purposes which the data is to be used for were not fixed or foreseeable when the relevant data was collected and the new purposes are compatible with the purposes for which the relevant data was originally collected. For example, new developments in the legal or technical sphere and new business models and services may lead to new processing purposes.

Personalised services allow us to offer you better, more practical and more secure services. To this end we use the data we have stored about you in order to determine your needs and interests. On this basis we can offer you more relevant content corresponding to your needs and interests. Of course, you still have access to all content. Personalisation allows you to see content which is more relevant to you more quickly, or content is specially presented to you (e.g. in the form of individual product recommendations).

Most of our personalised services require you to set up a customer account so that we can save data we collect on you at a central location.

Data which we collect about you is saved on your customer account, along with your customer number (customer ID). The customer number is a randomly generated sequence of numbers which does not contain any personal data. Your data is associated with your customer number, in order to link you to your customer account. The customer number also functions as a pseudonym.

Personalised content is generally selected on the basis of all data stored on your customer account.

If device and access data is used which is not saved on your customer account, these are only pseudonymised for the relevant personalisation (so e.g. in connection with your customer number, but not in connection with your named or other directly identifying profile data) for the duration of the usage.

Not used:

• Creditworthiness data
• Information for campaigns and surveys
• Job applications
• Notifications (e.g. from customer service)

You can view most of the data we have stored on your customer account at any time. If required you can also edit this data on your account and influence personalisation, perhaps by providing your preferences.

If personalisation is based on device and access data, you can prevent the collection of this data by deactivating the collection of this data by tracking tools. Please bear in mind, however, that you will receive less or no personalised content and services. Please bear in mind that the data used for personalised services are also needed for other purposes (including the provision of our services), in which case the collection of the data required will continue to be collected. However, the advertising presented to you will then not be personalised.

You can find the responsible service provider in the imprint of the relevant website or app.

We generally collect all the data which you directly share with us via our services.

Device and access data

Whenever you access our services and databases, we collect device and access data and record it in so-called server log files. The IP address it contains is anonymised shortly after the end of the relevant session, as soon as storage is no longer required to maintain the functionality of the relevant website.

If it is available and activated on your device, we also collect a device-specific ID number (e.g. a so-called “promo ID” if you are using an Android device or an “ad ID” if you are using an Apple device). This device ID is issued by the manufacturer of your operating system and can be read by websites and apps and used to present content on the basis of your usage habits. If you do not want this, you can deactivate it at any time in your device’s browser settings or system settings.

Login

We set up password-protected personal access for users who register for a customer account or another service. If you do not log out again after logging in with your login details, most services automatically keep you logged in. Depending on the type of service, a cookie or similar technology is used for this. This function allows you to use part of our services without having to log in again every time. For security reasons, however, you will be asked to enter your password again if, for example, you want to change your profile information or submit an order. You can find more information under “Personalised services”

Social Plug-ins

Our services may contain social plug-ins (“plug-ins”) from various social networks. These plug-ins allow you, for example, to share content or recommend products. The plug-ins are deactivated as standard and therefore do not send any data. You can activate the plug-ins by clicking on the corresponding button (e.g. “activate social media”. The plug-ins can also be deactivated again with a click. If the plug-ins are activated, your web browser sets up a direct connection to the web servers of the relevant social network. The content of the plug-ins is then transferred by the social network directly to your web browser and integrated by the latter into our website. Integrating the plug-ins allows the social network to receive the information that you have called up the relevant page of our internet offering and can collect your device and access data. If you are logged into the social network, the latter may also assign the visit to your account with the relevant social network. If you interact with the plug-ins, for example by clicking the Facebook “like” button or making a comment, the corresponding information will be transmitted by your browser directly to the social network and stored there. The purpose and scope of the data collection, and the further processing and use of the data by the particular social networks and your rights and configuration options concerning this to protect your privacy, can be found in the privacy notices of the respective social networks and websites. You can find the links to these below. Even if you are not registered with the social networks, websites with active plug-ins may send data to the networks. An active plug-in will place a cookie with an ID each time you call up the website. Because your web browser sends this cookie without being asked every time you connect to a server, the social network could in principle create a profile of which websites the user belonging to the ID had called up. And it would also be quite possible to assign this ID to a person, for example if they later registered with the social network.

Facebook social plug-ins

We use plug-ins by the social network facebook.com, operated by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA (“Facebook”), on several websites. You can find the link to Facebook’s Data Protection Declaration here: Facebook’s privacy policy.

Twitter social plug-ins

We use plug-ins by the social network Twitter, operated by Twitter Inc., 795 Folsom St., Suite 600, San Francisco, CA 94107, USA (“Twitter”), on several websites. You can find the link to Twitter’s privacy policy here: Twitter’s privacy policy.

Pinterest social plug-ins

We use plug-ins by the social network Pinterest, operated by Pinterest Inc., 651 Brannan Street, San Francisco, CA 94103, USA (“Pinterest”), on several websites. You can find the link to Pinterest’s privacy policy here: Pinterest’s privacy policy.

Social Logins

Our services may offer you the option of registering with us directly using your social network accounts. If you wish to use this function, you will first be forwarded to the relevant social network’s offering. There you will be asked to log in with your user name and password. Of course, we do not ourselves take note of your login details. If you are already logged in, this step will be skipped. The relevant social network then notifies you and asks you to confirm which data are transmitted to us (e.g. public profile, friends list, email address and current residence). We use the data transmitted to create your customer account, but will not, of course, save your friends list, for example. No further permanent connection between your customer account and your social network account will take place. We also receive social network data from the providers of the relevant social networks.

Shopping personalisation

Our services use the device and access data from the usage analysis, which are collected when you use our service, for shopping personalisation. Depending on the type of service, this may include common tracking technologies using tracking pixels and identification cookies or similar Ids (so-called tagging). In addition, our advertising partners may collect your device and access data in this way, in order to provide us with information on your interests and demographic data (such as age, gender, region) during your use of our services. This allows us to present you with advertising and/or particular offerings and services which correspond to your interests (for example product recommendations based on the fact that you have only viewed trainers in the last few days). Our goal when doing this is to make our offering as attractive to you as possible and to present you with advertising corresponding to your interest areas. Of course, you can continue to use all content and functions. This on-site optimisation does, however, allow us to first show you content and functions which are more relevant for you. On-site optimisation is carried out automatically by our systems, which recognise that users have repeatedly called up products and content from particular categories.

If you do not want on-site optimisation, you can deactivate this function at any time:

• To do this, please deactivate the “data processing” function (in the Zalando app you will find this function on the info menu under the point “About us”).
• In other services, please do this by deactivating web analysis or app analysis.

Info on website cookies

Our websites use cookies. Accepting cookies is not a prerequisite for using our websites. We would, however, like to point out that our websites can only function on a limited basis if you do not accept cookies. You can set your browser up in such a way that cookies are only saved if you agree to this.

The cookies used by our website may come from Zalando or advertising partners. If you only wish to accept the Zalando cookies, but not our advertising partners’ cookies, you can choose the corresponding setting in your browser (e.g. “block third-party cookies). The help function in your web browser’s menu bar generally shows you have to reject new cookies, and to turn off cookies which have already been received. We recommend that you completely log out after you finish using our website on shared computers which are set to accept cookies and Flash cookies.

Our services use three categories of cookies:

• Necessary cookies: These cookies are required for optimal navigation and operation of the website. For example, these cookies are used to implement the basket function, such that the goods in your basket stay saved while you continue with the purchase. The necessary cookies also serve to save particular inputs and settings which you have made so that you don’t have to constantly repeat them, and to adapt Zalando content to your individual interests. Only limited use of the website is possible without necessary cookies.
• Statistical cookies: These cookies collect device and access data to analyse the use of our website, such as which areas of the website are used how (so-called surfing behaviour), how fast content is loaded and whether errors occur. These cookies only contain anonymous or pseudonymous information and are only used to improve our website and to find out what our users are interested in, and to measure how effective our advertising is. Statistical cookies can be blocked without adversely affecting the navigation and operation of the website.
• Marketing cookies (“tracking cookies”): These cookies contain identifiers and collect device and access data, in order to adapt personalised advertising on Zalando websites to your individual interests. Our advertising partners who operate online advertising networks also collect device and access data on our websites. This allows us to display personalised advertising on other websites and in other providers’ apps which fits your interests (so-called retargeting). Marketing cookies can be blocked without adversely affecting the navigation and operation of the website. Shopping personalisation may, however, not be possible.

We have collected country-specific overviews of all cookies used in the Zalando shop. You can find these under “Information on individual websites”.

App stores/installation

Zalando apps are available on app platforms run by third parties, so-called app stores (e.g. Google Play and Apple App Store). Download may therefore require prior registration with the relevant app store. Zalando has no influence on the processing of your data in connection with your registration with and use of these app stores. The operator of the relevant app store therefore has full responsibility. Please get information if required from the relevant app store operator directly.

Sharing content

If your operating system has an integrated function for sharing app content, you can call this up in our apps via the share or recommend button in order to share content or recommend products. Depending on which functions your device or operating system has and how you have configured your device, you can also use social networks to share content.

We would like to point out that the share functions used by our app are operating system-side functions. We do not receive any information on the recipients and content of your communication. You can get more information on the share functions and your configuration options from the manufacturer of your device.

Which social networks are available to you for sharing content depends on which social networks you are a member of and how you have configured your membership account and device. You can find further information in the relevant privacy policies of the social networks you use.

Location-based services

The functions of some of our apps use your device’s location services to collect location information. This is for the purpose of offering you app-based services and content tailored to your current location. For example, an app can show you transactions in your area and suggest products to you which are suited to the weather at your current location. If you allow the app to access location services, your location will be regularly transmitted to us for this purposes. We do not use this data to produce any motion profiles.

Push service

Our apps can inform you using push notifications of particular events or topics even if you are not currently using the app. Push notifications are an app-specific form of notification which we can use to address you directly. If you do not want this, you can deactivate the push service at any time using your device settings and in the settings within the app.

If you activate the push notification service, your device will be assigned a device-specific push ID. For technical reasons, no push notifications can be sent without a push ID. Push Ids are only encrypted, randomly generated sequences of number.

System authorisations

For some functions, our apps must be able to access certain interfaces and data on your device. Depending on which operating system you use, this may require your express consent. Below we explain to you which authorisations (if these are relevant for the processing of your data) our apps may request and for which kind of functions these authorisations are required. You can change your authorisation settings in your devices’ system settings.

• Location services/location information: Authorisation for access to your device’s location services is required, so that an app can access the location determined by your device. If you do not allow access, the location-based display of content may not be possible, or may only be possible on a limited basis.
• Notifications/push notifications: Authorisation is required for the use of the push service. Some devices activate authorisation for all apps as standard.
• Access to saved photos: The authorisation is necessary so that an app can access saved photos (read access) or photos produced by an app can be saved on your device (write access).
• Camera: Authorisation is required so that an app can use your device’s camera function, perhaps to take photos or capture QR codes. The relevant app will only access the camera if you use the relevant function in the app.
• Requesting mobile data (iOS) or access to all networks and network connections (Android): When using or installing certain apps, these authorisations will be requested in order to allow the relevant app to transfer data via your device’s internet connection (by WLAN or data connection). This authorisation may be necessary in order to transfer inputs in the app, e.g. in the course of a search, to our servers.
• Changing, deleting or reading the content of USB memory devices/SD cards: These authorisations are required to allow the relevant app to store or read data on your device’s memory or any auxiliary storage. The relevant app will only read the data which was stored in connection with the use of this app.

Our websites and apps contain cookies and similar tracking technologies from advertising partners which operate an online advertising network. This also allows our advertising partners to collect your device and access data and to present you with personalised advertising on other websites and in other providers’ apps targeted to your interests (e.g. advertising based on which products you have previously viewed in the Zalando shop).

You can find further information under “How does Zalando use my data for advertising?”

You can deactivate the processing of your data for retargeting at any time:

• To do this, please deactivate the “Data processing” function in the Zalando shop. You can find this function in the Zalando app in the info menu under the point “About us”. In the Zalando web shop you can find this function directly next to the link to this Data Protection Declaration.
• In other services, please do this by deactivating usage analysis.
• For other websites and apps you can also deactivate retargeting by participating online advertising networks on the deactivation page of the European Interactive Digital Advertising Alliance (EDAA): Deactivate further advertising.

We use common tracking technologies to evaluate device and access data. This allows us to find out how our offering is being used by our users in general. We do this using identification cookies and similar identifiers. This allows us to find out, for example, which content and topics are particularly popular, when our services are used the most, from which regions (down to the city level) our services are used and which browsers and devices our users generally use.

We may also carry out so-called A/B tests in the course of usage analysis. A/B tests are a special kind of usage analysis. A/B testing (also known as split testing) is an approach to comparing two versions of a website or app in order to find out which version performs better, is more popular or lets users find their desired content quicker. Producing a version A and version B and testing both versions provides data which makes it easier and faster to make changes to services and content.

You can find out which tracking tools our websites and apps use under “Information on individual websites”.

You can also find information there on deactivating usage analysis.

You can deactivate the processing of your data for usage analysis at any time:

• To do this, please deactivate the “Data processing” function in the Zalando shop. You can find this function in the Zalando app in the info menu under the point “About us”. In the Zalando web shop you can find this function directly next to the link to this Data Protection Declaration.
• In other services, please do this by deactivating usage analysis.

When sending out our notifiable newsletters (such as the Zalando shop newsletter), we use the so-called double opt-in procedure or single opt-in procedure (country-dependent), i.e. we will only send you the newsletter if you have given explicit prior consent to us activating the newsletter. If a double opt-in is required in your country, you must also have confirmed that the email address you have shared with us belongs to you. For this purpose we will send you a notification email and ask you to confirm by clicking on one of the links in this email that you are the owner of the email address you have shared with us. We may waive this measure if you have already confirmed to us in this way for another purpose that you are the owner of this email address.

If you no longer wish to receive emails from us, you can withdraw your consent at any time without incurring any costs other than the transmission costs according to basic tariffs. A notification in text form (e.g. email, fax, letter) to the Zalando company responsible for the relevant newsletter is sufficient for this. Of course, you will also find an unsubscribe link in every newsletter.

If you subscribe to a newsletter, we automatically save your IP address and the time of your subscription and confirmation. This way we can prove that you actually subscribed and identify any unauthorised use of your email address.

We collect device and access data which arise when you interact with a newsletter. For this evaluation, the newsletters contain links to image files stored on our web servers. When you open a newsletter, your email programme loads these image files from our web server. We collect the device and access data which then arises in pseudonymised form under a randomly generated ID number (newsletter ID), which we will not use to identify you without your consent. This way we can understand whether and when you have opened which issues of a newsletter. The links contained in the newsletters likewise contain their newsletter ID so that we can determine which content you are interested in. We use the data collected here to create a user profile for your newsletter ID in order to personalise newsletter content according to your interests and usage habits and to statistically analyse how our users use the newsletter service. We connect this data to data which we collect within the framework of usage analysis.

This shopping personalisation is an integral component of the Zalando shop newsletter.

You can object to newsletter analysis at any time by deactivating the corresponding newsletter service. Of course, you will also find an unsubscribe link in every issue of our newsletter. You can also find further information under “Which data protection rights do I have?”

Alternatively, you can deactivate the display of images in your email programme. In this case, however, the newsletter will not be displayed to you in full.

The advertising formats used by Zalando and Zalando’s advertising partners include presentations in the Zalando shop (within the framework of on-site and in-app optimisation), adverts on social networks (e.g. Facebook ads, Instagram ads, YouTube video ads) and advertising spaces mediated via the online advertising networks used by Zalando such as DoubleClick by Google.

Zalando does not sell any personal data. When our advertising customers book a Zalando advertising format with Zalando Media Solutions GmbH, they do not receive any data which could be used to contact or identify you without your express consent. Our advertising customers only receive anonymous, aggregated reports with information on the effectiveness and reach of the advertising services we provide. These reports are based on Zalando Media Solutions GmbH’s own surveys, and sometimes also take into account summarised reports which we receive from our advertising partners and social networks. These show, for example, how our advertising services have affected sales to various groups of customers.

In creating target groups we use our own findings from data analysis on our users’ usage and purchasing behaviour and customers as well as our market research on user segmentation which we apply to the user data collected by Zalando. In doing this we especially consider aggregated, pseudonymised or anonymised shopping data, search histories, interests data and demographic profile data as well as device and access data.

Our advertising partners also have the option to provide us with their own data for user segmentation, which was collected by the advertising partners themselves. The advertising partners must undertake only to provide Zalando with aggregated, encrypted or anonymous data, so that we cannot assign the data to any particular person, especially any particular user of the Zalando shop. Some target groups are created on the basis of the users’ surfing behaviour. This is the case if advertising is only intended to be presented to users who have recently visited a particular website or searched for particular content.

We use the above information within the framework of on-site optimisation in order to present you with more relevant information and content when you search for products, call up your feed or visit a product area. On-site and in-app optimisation is based on cookies and similar identification technologies for the pseudonymous collection of device and access data. This data is not used to identify you personally, but rather to evaluate your usage pseudonymously. Your data is never permanently combined with other personal data we have stored on your person. This technology allows us to present you with products and/or particular offerings and services with content based on your device and access data (for example advertising geared to the fact that you have only viewed sports clothing in the last few days).

If you do not want on-site optimisation, you can deactivate this function at any time:

• To do this, please deactivate the “Data processing” function in the Zalando shop. You can find this function in the Zalando app in the info menu under the point “About us”. In the Zalando web shop you can find this function directly next to the link to this Data Protection Declaration.
• In other services, please do this by deactivating web analysis or app analysis. Please bear in mind that data used for on-site and in-app optimisation is also used for other purposes (including the provision of our services). The collection of the data used for this is therefore not prevented by deactivation. The advertising presented to you will, however, no longer be personalised.

If we advertise via advertising formats offered by social networks (e.g. YouTube, Facebook, Instagram), we have the option of forwarding encrypted information on Zalando users (e.g. device and access data such as advertising and cookie IDs, email addresses) which we believe belong to an advertising customer’s target group or show particular features (e.g. age group, region, interests).

The relevant social network will then - either on our behalf as an order processor or with the consent of the relevant user - decrypt the transmitted data and display the advertising booked by us to the user as part of his existing usage relationship with the relevant social network (if he is a member of the relevant social network).

If you do not want us to use your data to present you with personalised advertising on social networks, you can deactivate the forwarding of your data:

• To do this, please deactivate the “Data processing” function in the Zalando shop. You can find this function in the Zalando app in the info menu under the point “About us”. In the Zalando web shop you can find this function directly next to the link to this Data Protection Declaration.
• In other services, please do this by deactivating web analysis or app analysis.

If you have consented to the forwarding of your data to social networks, you can withdraw your consent at any time.

You may also have the option of deactivating the use of your data for personalised advertising by the social networks you use by directly contacting the relevant providers. For further information, directly contact:

Facebook (Facebook, Instagram):

• Information on Facebook adverts
• Advertising settings for Facebook

Google (Google advertising network, YouTube, Google search):

• Information on Google adverts
• Advertising settings for Google

Advertising partners which run an online advertising network may use cookies and similar technologies to pseudonymously collect your usage behaviour using device and access data on the Zalando shop and in other providers’ apps. These advertising partners use the data collected in order to identify the probability of you belonging to the target group we are addressing, and take this into account when choosing the adverts on the advertising spaces mediated via their online advertising network. This standard internet technology is referred to as retargeting. Retargeting allows us to run advertising which is as relevant to you as possible and to measure the efficiency and reach of the advertising materials, but also to check our advertising partners’ bills for campaigns we are running.

You can get further information on the operators of the respective advertising spaces and the online advertising networks charged with mediating them. You can find an overview of advertising partners and information on deactivation under “Information on individual websites”.

You can deactivate the processing of your data for retargeting at any time:

• To do this, please deactivate the “Data processing” function in the Zalando shop. You can find this function in the Zalando app in the info menu under the point “About us”. On the Zalando web shop you can find this function directly next to the link which you used to reach this Data Protection Declaration.
• In other services, please do this by deactivating usage analysis.
• You can deactivate retargeting by participating online advertising networks for our websites on the deactivation page of the European Interactive Digital Advertising Alliance (EDAA): Deactivate further advertising.

Please bear in mind that the data used for retargeting is also needed for other purposes (including the provision of our services). The collection of the data used for this is therefore not prevented by deactivation. The advertising presented to you will then not, however, be personalised.

Many systems and technologies are shared within Zalando Group. This allows us to offer you a more economical, secure, unified and personalised service. Therefore, companies within Zalando group which require access to your data to fulfil our contractual and legal obligations, or to fulfil their respective functions within Zalando group, receive this access.

We work with external shipping companies (e.g. DHL) to deliver orders. These shipping companies receive the following data to execute the relevant order:

• Your name
• Your delivery address
• your post number if applicable (if you wish to have the order delivered to a DHL packing station)
• your email address if applicable (if the shipping company wishes to inform you of the provisional delivery date by email)

Within the framework of the Zalando partner programme we allow other retailers (so-called Zalando partners) to sell their products (so-called Zalando partner items) via the Zalando shop. The Zalando shop serves as a sales platform for the mediation of purchase agreements within the framework of the Zalando partner programme. “Sale and shipping by our partner” is then displayed under the relevant Zalando partner item, along with the name of the relevant Zalando partner.

When you order a Zalando partner item, the item is generally dispatched by the relevant Zalando partner. We forward your shopping data to the Zalando partner for this purpose. This includes:

• Details on the Zalando partner items ordered
• Your name
• Your delivery address

In some cases or countries we also transmit your email address or telephone number to a partner, but only where this is necessary to facilitate the delivery of the item to you.

Even if you purchase a Zalando partner item, Zalando remains responsible for processing your data. Your data will neither be processed together with a Zalando partner nor on behalf of a Zalando partner. Zalando will ensure that the Zalando partner programme does not give Zalando partners any control over the processing of your data. When you purchase a Zalando partner’s items or goods from Zalando, Zalando only transmits to the Zalando partner the data listed above which the Zalando partner requires in order to fulfil its service to you, i.e. normally in order to deliver the purchased goods to you. When Zalando transmits your data to a Zalando partner for the reasons above, Zalando will ensure in the contractual agreements with the partners that the Zalando partner only processes your data for the above purposes.

Please bear in mind that the Zalando partners have their own data protection provisions. You can usually find these on the relevant partner pages of the Zalando shop and/or on the websites of the relevant Zalando partner. Zalando is not responsible for its partners’ data protection provisions and data processing practices.

We work with technical service providers in order to be able to provide our services. These service providers include, for example, Telekom Deutschland GmbH, Salesforce.com EMEA Ltd. and Amazon Web Services, Inc. If they process your data outside the European Union, this may mean that your data is transmitted to a country with a lower data protection standard than the European Union. In such cases Zalando will ensure that the relevant service providers contractually or otherwise guarantee an equivalent data protection level.

Cooperation with external credit agencies for fraud prevention, payment method selection and credit checks is country-specific, in order to take account of country-specific features and requirements. Under Country-specific information you can find information on which external payment service providers and credit agencies we work with in which countries. There you can also find special privacy policies which we provide you with on behalf of the relevant payment service providers and credit agencies.

As part of advertising campaigns we forward data to social network providers within the scope of data protection law. You can find further information under “How does Zalando use my data for advertising?”.

If we are obliged by an official or court decision or it is for prosecution purposes, we will if necessary forward your data to prosecution authorities or other third parties.

The service provider of credit checks for consumers in Germany is Infoscore Consumer Data GmbH, Rheinstraße 99, 76532 Baden-Baden, Germany.

You can find detailed privacy policies for Infoscore Consumer Data GmbH in the sense of Article 14 GDPR, especially information on the business purpose, the purposes of data storage, data recipients as well as other data protection rights against Infoscore Consumer Data GmbH here and at https://finance.arvato.com/icdinfoblatt.

The service provider of credit checks for consumers in Austria is CRIF Bürgel GmbH, Radlkoferstraße 2, 81373 Munich, Germany

You can find detailed privacy policies for CRIF Bürgel GmbH in the sense of Article 14 GDPR, especially information on the business purpose, the purposes of data storage, data recipients as well as other data protection rights against CRIF Bürgel GmbH here: https://www.crifbuergel.de/sites/default/files/documents/informationsblatt_dsgvo.pdf.

The service provider of credit checks for consumers in Switzerland is CRIF Bürgel GmbH, Radlkoferstraße 2, 81373 Munich, Germany

You can find detailed privacy policies for CRIF Bürgel GmbH in the sense of Article 14 GDPR, especially information on the business purpose, the purposes of data storage, data recipients as well as other data protection rights against CRIF Bürgel GmbH here: https://www.crifbuergel.de/sites/default/files/documents/informationsblatt_dsgvo.pdf.

The service provider of credit checks for consumers in the Netherlands is Experian Nederland B.V., Grote Marktstraat 49, 2511 BH The Hague, Netherlands

The service provider of credit checks for consumers in Belgium is Infoscore Consumer Data GmbH, Rheinstraße 99, 76532 Baden-Baden, Germany..

The service provider of credit checks for consumers in Sweden is UC AB, Årstaängsvägen 21B, 117 88 Stockholm, Sweden

The service provider of credit checks for consumers in Norway is Experian AS, Karenslyst Alle 8 B, PO Box 5275 Majorstuen, 0303 Oslo, Norway

The service provider of credit checks for consumers in Finland is Suomen Asiakastieto Oy, Työpajankatu 10 A, 00580 Helsinki, Finland