Data protection

1) Information about the collection of personal data and contact details of the person responsible 1.1 We are pleased that you are visiting our website and thank you for your interest. In the following we will inform you about how your personal data is handled when you use our website. Personal data is all data with which you can be personally identified. 1.2 The person responsible for data processing on this website within the meaning of the General Data Protection Regulation (GDPR) is Michael Wiese, Am Werder 17, 21335 Lüneburg. Germany. Tel.: 49 (0) 163-6397738, Mail: michael@full-circle.de. The person responsible for the processing of personal data is the natural or legal person who alone or jointly with others decides on the purposes and means of processing personal data. 1.3 For security reasons and to protect the transmission of personal data and other confidential content (e.g. orders or inquiries to the person responsible), this website uses SSL or TLS encryption. You can recognize an encrypted connection by the character string “https://” and the lock symbol in your browser line.

2) Data collection when visiting our website If you simply use our website for information purposes, i.e. if you do not register or otherwise provide us with information, we only collect data that your browser transmits to our server (so-called “server log files”). When you access our website, we collect the following data, which is technically necessary for us to display the website to you: – The website you visited – Date and time of access – Amount of data sent in bytes – Source/reference from which you accessed the page – Browser used – Operating system used – IP address used (if applicable: in anonymized form) Processing takes place in accordance with Art. 6 Para. 1 lit. f GDPR on the basis of our legitimate interest in improving the stability and functionality of our website. The data will not be passed on or used in any other way. However, we reserve the right to subsequently check the server log files if there are concrete indications of illegal use.

3) Cookies In order to make visiting our website more attractive and to enable the use of certain functions, we use so-called cookies on various pages. These are small text files that are stored on your device. Some of the cookies we use are deleted after the end of the browser session, i.e. after you close your browser (so-called session cookies). Other cookies remain on your device and enable your browser to be recognized the next time you visit (so-called persistent cookies). If cookies are set, they collect and process certain user information to an individual extent, such as browser and location data as well as IP address values. Persistent cookies are automatically deleted after a specified period of time, which can vary depending on the cookie. You can find out how long the respective cookie is stored for in the overview of the cookie settings in your web browser. In some cases, cookies are used to simplify the ordering process by storing settings (e.g. remembering the contents of a virtual shopping cart for a later visit to the website). If personal data is also processed through individual cookies used by us, the processing is carried out in accordance with Art. 6 Paragraph 1 Letter b GDPR either to execute the contract, in accordance with Art. 6 Paragraph 1 Letter a GDPR in the event of consent being given, or in accordance with Art. 6 Paragraph 1 Letter f GDPR to safeguard our legitimate interests in the best possible functionality of the website and a customer-friendly and effective design of the site visit. Please note that you can set your browser so that you are informed about the setting of cookies and can decide individually whether to accept them or exclude the acceptance of cookies in certain cases or in general. Each browser differs in the way it manages cookie settings. This is described in the help menu of each browser, which explains how you can change your cookie settings. You can find these for the respective browsers under the following links: Internet Explorer: https://support.microsoft.com/de-de/help/17442/windows-internet-explorer-delete-manage-cookies Firefox: https://support.mozilla.org/de/kb/cookies-erlauben-und-ablehnen Chrome: https://support.google.com/chrome/answer/95647?hl=de&hlrm=en Safari: https://support.apple.com/de-de/guide/safari/sfri11471/mac Opera: https://help.opera.com/de/latest/web-preferences/#cookies Please note that if you do not accept cookies, the functionality of our website may be limited.

4) Contact When you contact us (e.g. via contact form or email), personal data is collected. The data collected when you use a contact form can be seen from the respective contact form. This data is stored and used solely for the purpose of answering your query or for establishing contact and the associated technical administration. The legal basis for processing this data is our legitimate interest in answering your query in accordance with Art. 6 Paragraph 1 Letter f GDPR. If your contact is aimed at concluding a contract, the additional legal basis for processing is Art. 6 Paragraph 1 Letter b GDPR. Your data will be deleted after your query has been processed. This is the case if the circumstances indicate that the matter in question has been conclusively clarified and provided that there are no statutory retention periods to the contrary.

5) Data processing when opening a customer account and for contract processing In accordance with Art. 6 Paragraph 1 Letter b of GDPR, personal data will continue to be collected and processed if you provide it to us to carry out a contract or when opening a customer account. Which data is collected can be seen from the respective input forms. Your customer account can be deleted at any time and can be done by sending a message to the above-mentioned address of the person responsible. We store and use the data you provide to process the contract. After the contract has been fully processed or your customer account has been deleted, your data will be blocked with regard to tax and commercial retention periods and deleted after these periods have expired, unless you have expressly consented to further use of your data or we have reserved the right to further use of the data that is permitted by law.

6) Use of customer data for direct advertising Sending the e-mail newsletter to existing customers If you have provided us with your e-mail address when purchasing goods or services, we reserve the right to regularly send you offers for similar goods or services from our range to those you have already purchased. In accordance with Section 7 Paragraph 3 of the Unfair Competition Act, we do not need to obtain your separate consent for this. In this respect, data processing is carried out solely on the basis of our legitimate interest in personalized direct advertising in accordance with Art. 6 Paragraph 1 Letter f of GDPR. If you have initially objected to the use of your e-mail address for this purpose, we will not send you any e-mails. You are entitled to object to the use of your e-mail address for the aforementioned advertising purpose at any time with effect for the future by notifying the person responsible named at the beginning. You will only incur transmission costs according to the basic rates. After receipt of your objection, the use of your e-mail address for advertising purposes will be stopped immediately.

7) Data processing for order processing 7.1 To process your order, we work with the following service provider(s), who support us in whole or in part in the implementation of concluded contracts. Certain personal data is transmitted to these service providers in accordance with the following information. The personal data we collect is passed on to the transport company commissioned with the delivery as part of the contract processing, insofar as this is necessary for the delivery of the goods. We pass on your payment details to the commissioned credit institution as part of the payment processing, insofar as this is necessary for the payment processing. If payment service providers are used, we will inform you explicitly about this below. The legal basis for the transfer of data is Art. 6 Paragraph 1 Letter b of GDPR. 7.2 Transfer of personal data to shipping service providers - DHL If the goods are delivered by the transport service provider DHL (DHL Paket GmbH, Sträßchensweg 10, 53113 Bonn), we will pass on your e-mail address to DHL in accordance with Art. 6 Paragraph 1 Letter a of GDPR before the goods are delivered for the purpose of coordinating a delivery date or to notify you of the delivery, provided that you have given your express consent to this during the ordering process. Otherwise, we will only pass on the name of the recipient and the delivery address to DHL for the purpose of delivery in accordance with Art. 6 Paragraph 1 Letter b of GDPR. The data will only be passed on if this is necessary for the delivery of the goods. In this case, prior coordination of the delivery date with DHL or the delivery notification is not possible. Consent can be revoked at any time with future effect to the person responsible named above or to the transport service provider DHL. – Hermes If the goods are delivered by the transport service provider Hermes (Hermes Logistik Gruppe Deutschland GmbH, Essener Straße 89, 22419 Hamburg), we will pass on your e-mail address to Hermes before the goods are delivered in accordance with Art. 6 Paragraph 1 Letter a of GDPR for the purpose of coordinating a delivery date or to announce the delivery, provided that you have given your express consent to this during the ordering process. Otherwise, we will only pass on the name of the recipient and the delivery address to Hermes for the purpose of delivery in accordance with Art. 6 Paragraph 1 Letter b of GDPR. The information will only be passed on if this is necessary for the delivery of the goods. In this case, it is not possible to coordinate the delivery date with Hermes in advance or to transmit status information on the delivery of the shipment. Consent can be revoked at any time with future effect to the person responsible named above or to the transport service provider Hermes.

8) Tools and miscellaneous 8.1 sevDesk To handle our accounting, we use the sevDesk service, the cloud-based accounting software from sevDesk GmbH, Hauptstraße 115, 77652 Offenburg. SevDesk processes incoming and outgoing invoices and, if applicable, our company's bank transactions in order to automatically record invoices, match them to transactions and use this to create financial accounting in a partially automated process. If personal data is also processed in this process, the processing is carried out in accordance with Art. 6 Para. 1 lit. f GDPR on the basis of our legitimate interest in the efficient organization and documentation of our business transactions. You can find more information about sevDesk GmbH, the automated processing of data and the data protection regulations at https://sevdesk.de/sicherheit-datenschutz/ 8.2 Google Customer Reviews (formerly Google Certified Dealer Program) We work with Google as part of the “Google Customer Reviews” program. The provider is Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland (“Google”). This program gives us the opportunity to obtain customer reviews from users of our website. After making a purchase on our website, you will be asked whether you would like to take part in an email survey from Google. If you give your consent in accordance with Art. 6 Paragraph 1 Letter a of GDPR, we will transmit your email address to Google. You will receive an email from Google Customer Reviews asking you to rate the purchasing experience on our website. The rating you submit will then be summarized with our other ratings and displayed in our Google Customer Reviews logo and in our Merchant Center dashboard. Your rating will also be used for Google Seller Ratings. Using Google Customer Reviews may also result in personal data being transferred to Google LLC servers in the USA. You can revoke your consent at any time by sending a message to the data controller or to Google. Further information on Google's data protection in connection with the Google Customer Reviews program can be found at the following link: https://support.google.com/merchants/answer/7188525?hl=de Further information on the data protection of Google Seller Reviews can be found at this link: https://support.google.com/google-ads/answer/2375474

9) Rights of the data subject 9.1 The applicable data protection law grants you comprehensive rights as a data subject (rights to information and intervention) vis-à-vis the controller with regard to the processing of your personal data, about which we will inform you below: - Right to information in accordance with Art. 15 GDPR: In particular, you have the right to information about your personal data processed by us, the purposes of the processing, the categories of personal data processed, the recipients or categories of recipients to whom your data has been or will be disclosed, the planned storage period or the criteria for determining the storage period, the existence of a right to rectification, erasure, restriction of processing, objection to processing, complaint to a supervisory authority, the origin of your data if it was not collected from you by us, the existence of automated decision-making including profiling and, if applicable, meaningful information about the logic involved and the scope and intended effects of such processing concerning you, as well as your right to be informed of the guarantees in accordance with Art. 46 GDPR when your data is forwarded to third countries; – Right to rectification in accordance with Art. 16 GDPR: You have the right to have inaccurate data concerning you rectified immediately and/or to have incomplete data stored by us completed; – Right to erasure in accordance with Art. 17 GDPR: You have the right to request that your personal data be erased if the requirements of Art. 17 Para. 1 GDPR are met. However, this right does not apply in particular if processing is necessary to exercise the right to freedom of expression and information, to fulfill a legal obligation, for reasons of public interest or to assert, exercise or defend legal claims; – Right to restriction of processing in accordance with Art. 18 GDPR: You have the right to request that the processing of your personal data be restricted as long as the accuracy of your data, which you dispute, is being verified, if you refuse to delete your data due to inadmissible data processing and instead request that the processing of your data be restricted, if you need your data to assert, exercise or defend legal claims after we no longer need this data after the purpose has been achieved, or if you have lodged an objection for reasons related to your particular situation, as long as it has not yet been determined whether our legitimate reasons prevail; – Right to information in accordance with Art. 19 GDPR: If you have asserted your right to rectification, erasure or restriction of processing vis-à-vis the responsible party, this party is obliged to inform all recipients to whom the personal data concerning you was disclosed of said rectification, erasure or restriction of processing, unless doing so should prove impossible or involve disproportionate expenditure. You have the right to be informed of these recipients. – Right to data portability in accordance with Art. 20 GDPR: You have the right to receive your personal data that you have provided to us in a structured, common and machine-readable format or to request that it be transmitted to another controller, provided this is technically feasible; – Right to revoke consent granted in accordance with Art. 7 Para. 3 GDPR: You have the right to revoke your consent to the processing of data at any time with effect for the future. In the event of revocation, we will delete the data concerned immediately, provided that further processing cannot be based on a legal basis for processing without consent. The revocation of the consent does not affect the legality of the processing carried out on the basis of the consent up to the time of revocation; – Right to complain in accordance with Art. 77 GDPR: If you believe that the processing of personal data concerning you violates the GDPR, you have the right to complain to a supervisory authority, in particular in the Member State of your residence, place of work or place of the alleged violation, without prejudice to any other administrative or judicial remedy. 9.2 RIGHT TO OBJECT IF WE PROCESS YOUR PERSONAL DATA BASED ON OUR OVERRIDING LEGITIMATE INTEREST AS A PART OF A BALANCE OF INTERESTS, YOU HAVE THE RIGHT TO OBJECT TO THIS PROCESSING AT ANY TIME FOR REASONS ARISING FROM YOUR PARTICULAR SITUATION, WITH EFFECT FOR THE FUTURE. IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL STOP PROCESSING THE DATA IN QUESTION. HOWEVER, WE RESERVE THE RIGHT TO CONTINUE PROCESSING IF WE CAN PROVE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING WHICH OVERRIDE YOUR INTERESTS, FUNDAMENTAL RIGHTS AND FREEDOMS, OR IF THE PROCESSING SERVES THE ASSERTION, EXERCISE OR DEFENSE OF LEGAL CLAIMS. IF YOUR PERSONAL DATA IS PROCESSED BY US IN ORDER TO CARRY OUT DIRECT MARKETING, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF PERSONAL DATA CONCERNING YOU FOR THE PURPOSE OF SUCH ADVERTISING. YOU CAN EXERCISE YOUR RIGHT OF OBJECTION AS DESCRIBED ABOVE. IF YOU EXERCISE YOUR RIGHT OF OBJECTION, WE WILL STOP PROCESSING THE DATA CONCERNED FOR DIRECT MARKETING PURPOSES.

10) Duration of storage of personal data The duration of storage of personal data is determined by the respective legal basis, the purpose of processing and - if applicable - also by the respective statutory retention period (e.g. retention periods under commercial and tax law). When personal data is processed on the basis of an express consent in accordance with Art. 6 Para. 1 lit. a GDPR, this data is stored until the data subject revokes his or her consent. If statutory retention periods exist for data that is processed within the framework of legal or quasi-legal obligations on the basis of Art. 6 Para. 1 lit. b GDPR, this data is routinely deleted after the retention periods have expired, provided that it is no longer required to fulfill or initiate a contract and/or we have no legitimate interest in continuing to store the data. When personal data is processed on the basis of Art. 6 (1) (f) GDPR, this data will be stored until the data subject exercises his or her right of objection in accordance with Art. 21 (1) GDPR, unless we can demonstrate compelling legitimate grounds for the processing which outweigh the interests, rights and freedoms of the data subject, or the processing serves to assert, exercise or defend legal claims. When personal data is processed for the purposes of direct marketing on the basis of Art. 6 (1) (f) GDPR, this data will be stored until the data subject exercises his or her right of objection in accordance with Art. 21 (2) GDPR. Unless the other information in this declaration on specific processing situations indicates otherwise, stored personal data will otherwise be deleted when it is no longer necessary for the purposes for which it was collected or otherwise processed.