We, Oscar Oweson (“we”, “us” or “our”), are committed to protecting your privacy and we have created this privacy policy (“Privacy Policy”) to let you know what to expect when you interact with us on the versanelle.com website (the “Website”), use our services or order products (collectively “Services”).

We will collect, process, and use personal data concerning you exclusively in compliance with the following Privacy Policy. The term “personal data” is defined in this context as any item of individual information concerning the personal or material circumstances of an identified or identifiable person, e.g. your name, your telephone number, your address as well as other information you provide to us when communicating with us (“Personal Data”).

I. Controller

Versanelle will function as the “controller” within the meaning of Article 4 number 7 of Regulation (EU) 2016/679, also known as the “General Data Protection Regulation” (“GDPR”).

II. Collection and storage of Personal Data; manner and purpose of their usage

1. Processing of data for usage of the Website

Whenever you access our Website through your browser, respectively via your mobile terminal device, we will collect only the Personal Data which your browser, respectively your mobile terminal device, automatically transmits to us so as to allow you to visit the Website and to ensure system stability and security. This may include, in particular:

• Your IP address; • Your device’s identifier, i.e. the unique ID number of your terminal device; • The content, date, and time of the access request; • The time zone of the requesting computer, respectively of the mobile terminal device; • The website from which the access request is being referred; • The web page for which access is being requested; • The http status code; • The data volume transmitted; • Your browser ID; • Your operating system; • The language and version of your browser software; as well as • The Advertising Identifier (IDFA).

Processing this data will serve the following purposes:

• To establish a trouble-free connection to the Website; • To display our goods and services; • To ensure the usability of our Website; • To analyze system stability and security; and • To fulfill additional administrative objectives.

The legal basis for this processing of the Personal Data concerning you is Article 6 paragraph 1 sentence 1 lit. f) of the GDPR. Our legitimate interest in this context results from the aforementioned data processing purposes.

2. Data processing when the contact form is used

We give you the option of contacting us by means of the “Contact” form provided on the Website. To use this form, you must fill in your name and a valid email address. Processing these data serves our legitimate interest in providing proper answers to your contact inquiries and is therefore performed on the basis of Article 6 paragraph 1 sentence 1 lit. f) of the GDPR.

3. Data processing for purchasing our goods and using our services

If you wish to purchase our goods and use our services, you may be asked at various times to provide us with Personal Data such as the following:

• Your name; • Your postal address; • Your email address, • Your telephone number or mobile phone number; and • Your credit card information.

We will process the Personal Data concerning you for the following purposes, and said Personal Data are required for these purposes:

• To fulfill contractual obligations, respectively to perform pre-contractual measures, in accordance with Article 6 paragraph 1 sentence 1 lit. b) of the GDPR, i.e. so as to be able to transact your purchases, process your payments, provide you with customer service, correspond with you, handle claims asserted by you or us, assure the technical administration of our Website, and manage our customer data; • To fulfill statutory requirements in accordance with Art 6 paragraph 1 sentence 1 lit. c) of the GDPR or to serve the public interest in accordance with Article 6 paragraph 1 sentence 1 lit. e) of the GDPR, i.e. so as to protect both you and us (including our affiliated companies) against fraud.

III. Forwarding data concerning you to processors and third parties

We carefully select service providers and instruct them duly, they are bound by our instructions and are regularly monitored and checked.

We may transfer the Personal Data concerning you to third parties (suppliers, sub-contractors, shipping companies, the credit institutions we have contracted for payment settlement or other payment service providers) insofar as this is required for our contractual performance pursuant to Article 6 paragraph 1 sentence 1 lit. b) of the GDPR, respectively in order to pursue our legitimate interests pursuant to Article 6 paragraph 1 sentence 1 lit. f) of the GDPR.

IV. Transfers of Personal Data to third countries

Insofar as we transmit Personal Data to countries located outside of the European Economic Area (“EEA”), we will ensure that the data recipient guarantees an adequate level of data protection within the meaning of Article 45 of the GDPR. If no adequacy decision is available, Versanelle will strive to ensure that the data recipient has put in place appropriate safeguards within the meaning of Article 46 of the GDPR and specifically utilizes the standard contractual clauses of the European Union for the transfer of data into non-EU third countries in their respectively current version.

When it comes to transferring data to the United States, Versanelle will strive to ensure that the data recipient enters into obligation to follow and observe the principles of the Privacy Shield Framework (i.e. principles setting forth minimum standards for the handling of Personal Data).

V. Use of cookies

Versanelle does not use cookies. In the event that cookies are set unbeknownst to us on your device or browser we do not take any responsibility for the consequences.

For further information on these setting changes, please see www.allaboutcookies.org/manage-cookies/.

VI. Duration of storage

We will store the Personal Data concerning you for as long as required to fulfill the respective storage purpose. Once this is no longer the case, we will erase your data unless we are bound to observe a longer retention period in accordance with Article 6 paragraph 1 sentence 1 lit. c) of the GDPR, namely on the basis of tax laws, commercial laws, or other statutory archiving/documentation obligations, or unless you have consented to an extended storage period in accordance with Article 6 paragraph 1 sentence 1 lit. a) of the GDPR.

VII. Your rights

In accordance with Article 15 of the GDPR, you are entitled to obtain access at any time to any Personal Data of yours that are being stored by us. In particular, you may request information about any of following matters: the processing purposes involved; the categories of data regarding you being stored; the categories of recipients of such data; the planned storage period; the existence of a right to demand rectification, erasure, restriction of processing or a right to object; the existence of a right to lodge a complaint with a supervisory authority; the origin of your data, insofar as they were not obtained from you; as well as the existence of an automated decision-making process, including profiling; you also have the right to request explanatory details.

In addition, you can demand the rectification of incorrect data pursuant to Article 16 of the GDPR, as well as the erasure of Personal Data pursuant to Article 17 of the GDPR insofar as their processing is not required to exercise the right of freedom of expression and information, to fulfill a statutory obligation, to serve the public interest, or to assert, enforce or defend legal claims.

You furthermore have the right, pursuant to Article 18 of the GDPR, to demand that a block or restriction be placed on the processing of the Personal Data concerning you insofar as: their correctness is disputed by you; the processing is unlawful but you object to the erasure of the data; we no longer require the data but you still require it in order to assert, enforce or defend legal claims; or you have expressly objected against the data being processed pursuant to Article 21 of the GDPR.

Furthermore, you are entitled pursuant to Article 20 of the GDPR to obtain the Personal Data you have provided to us in a structured, commonly used, and machine-readable format, or to demand that such data be transmitted to some other authorized party.

Finally, insofar as the Personal Data concerning you are being processed on the basis of legitimate interests pursuant to Article 6 paragraph 1 sentence 1 lit. f) of the GDPR, you have the right, pursuant to Article 21 of the GDPR, to at any time object to having the Personal Data concerning you processed, on grounds relating to your particular situation or insofar as your objection specifically refers to processing for purposes of direct advertising. In the latter case, you will enjoy a fundamental right to object that will be honored by Versanelle without your having to state grounds in connection with a particular personal situation.

If you believe that our processing of the Personal Data concerning you is not consistent with applicable law, you may lodge a complaint with a competent supervisory authority pursuant to Article 77 of the GDPR.

If the processing of your data is based on a declaration of consent you have granted pursuant to Article 6 paragraph 1 lit. a) of the GDPR, you have the right to any time withdraw said consent with effect for the future.

VIII. Data security

In the course of visits to our Website, we employ the widely-used SSL process in conjunction with the respectively highest level of encryption supported by your browser.

In all other respects, we take appropriate technical and organizational security measures in order to protect your data against manipulation, loss, destruction, and unauthorized access by third parties. Our security measures are kept consistently up-to-date based on the latest state of the technical art.

IX. Your contact for data protection matters

If you have questions about how the Personal Data concerning you is collected, processed or used, if you wish to obtain information regarding your data or to have them rectified, blocked or erased, or if you wish to withdraw your consent, please contact our Data Protection Officer at: work@oweson.xyz