Last updated on: 04.07.2022
This Data Protection Information provides information on the processing of your personal data whenever you visit the HIP Campers website (hereinafter “HIP Campers”, “we” or “us”) and when purchasing goods from said website.
1. Scope, data controller, data protection officer and definitions
1.1. Scope of this Data Protection Information
This Data Protection Information applies to the use of the HIP Campers website, including the online shop and any measures connected for the execution and rescission of an online purchase, the creation of a customer account, the newsletter dispatch, further informative emails and customer services, and for our marketing activities on third-party websites.
1.2. The Controller for the processing of your personal data
Unless otherwise specified in this Data Protection Information, the Controller for the processing of your personal data is:
Pillar Ltd.
62 Shumako Street
1434 Sofia
Bulgaria, privacy@hipcampers.com.
1.3. Contact details of the Data Protection Officer
Data Protection Officer
Pillar Ltd.
62 Shumako Street
1434 Sofia
Bulgaria
privacy@hipcampers.com
1.4. Definitions
This Data Protection Information is based on the following terms under data protection law, which we have defined to facilitate understanding:
- GDPR means Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).
- Recipient means a natural person or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular enquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by the public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.
Examples of possible recipients: Banks/payment providers, logistic firms and ship-ping service providers and IT services providers; for more information please refer to Section 4)
- Personal data means any information relating to an identified or identifiable natural person ("data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Examples of personal data: Name, contact details, bank or credit card details.
- Controller means the natural person or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
For the data processing activities described in this Data Protection Information, the Controller is Pillar Ltd.
- Processing means any operation or set of operations which is on personal data or on sets of personal data, whether or not by automated means such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
2. Purposes and legal bases of our processing of your personal data
2.1. Processing of your data when you visit our website
If you visit our website in order to find out about products and services without registering for a customer account, purchasing products in our online shop or otherwise actively transferring information to us (purely for informational purposes), we process your personal data for the following purposes and by virtue of the following legal bases:
2.1.1. Provision of websites and IT security
We process your personal data that are technically necessary to allow us to provide our websites to you and to guarantee stability and security when you visit our websites. This includes the following personal data:
- IP address
- type and version of browser
- operating system and platform
- the complete Uniform Resource Locator (URL)
These personal data will be stored for security purposes in server log files, which will automatically be deleted after 7 days. This data processing is necessary for the purpose of enabling you to use our websites as well as for the purposes of our legitimate interest to guarantee IT security.
2.1.2. Provision of localised content
We also process your personal data that are technically necessary to allow us to provide you with a localised version of the websites, in particular with regard to the language. This data processing is necessary for the purpose of our legitimate interest to adapt our website to your needs.
2.1.3. Google Analytics
We use Google Analytics on our websites, a web analysis service of Google Inc. (“Google”). Google Analytics uses cookies (for more information on cookies please refer to Section 2.1.5 and our
Cookie Settings information) that allow an analysis to be made on the usage of our websites. The information generated by the cookie on the use of our websites is, as a rule, transferred to a server of Google in the USA, where it is stored. On behalf of HIP Campers, Google will use this information in order to evaluate the use of the websites, to prepare reports on the web-site activities, to analyze the impact and improve the customization of our digital advertisements, and to provide further services to HIP Campers connected with the use of the websites and of the Internet. The IP address transferred from the user’s browser with regard to Google Analytics is not merged with other data by Google. Further information on terms of use and data protection can be found under:
https://policies.google.com/terms
https://policies.google.com/privacy.
This data processing is necessary for the purpose of our legitimate interest to carry out analyses in order to improve our website and our products, and to advertise our products on the Internet in a customized and efficient way.
Google Analytics Opt-out:
You can prevent the processing of your usage data (including your IP address) by Google Analytics generally, by downloading and installing the browser add-on available at the following link:
https://tools.google.com/dlpage/gaoptout
In addition, you can also prevent Google Analytics from collecting your usage data on our websites by clicking on the following link:
Click here to opt-out of Google Analytics
In this case a persistent opt-out cookie (name: “ga-disable-UA-[…]”) is set in your current used browser, that prevents your data from being recorded in the future when you visit our website with this specific browser. If you use another browser, Google Analytics will be in principle enabled, unless the opt-out cookie is also set in this browser. Please note, that Google Analytics will be enabled again, if you delete the abovementioned opt-out cookie in your browser.
2.1.4. Conversion tracking and display advertising/retargeting on third-party websites
When you visit our website, tags and cookies are set by our retargeting provider(s) to track which products you have viewed or purchased on our websites. When you visit our website from a mobile device with location-enabled services, we may collect and process information about your actual location, like GPS signals sent by a mobile device. We may also use various technologies to determine location, such as sensor data from your device that may, for example, provide information on nearby Wi-Fi access points and cell towers.
With the help of this information we can then show you individual offers of HIP Campers' products on third-party websites via our retargeting provider(s), promotions that are relevant to you at that location, and analyze the results to further improve our advertising. The information we collect and use relates to how a device is being used to visit our websites and NOT about the person using the device.
For further details on the processing of data by our retargeting provider(s) listed below, please refer to the corresponding privacy policy / policies:
This data processing is necessary for the purpose of our legitimate interest to advertise our products on the Internet in a customized and efficient way.
Retargeting Opt-out:
You can object to this data processing by clicking on the following opt-out link(s) of the respective retargeting provider(s).
2.1.5. Use of cookies
On our website we use cookies. Cookies are small text files that are stored in the browsers of your end devices whenever you visit our websites. Through cookies, your actions and settings on our websites can be tracked, stored and recognized for the duration of the browser session or even after this. In addition to this, cookies and their respective cookie IDs allow your browser to be recognised. For example, after leaving the website, you can reconstruct the content of your shopping card or be shown the last seen products. As a rule, cookies make your browsing experience better. However, you may prefer to disable cookies on this site and on others.
For more information about the use of cookies on our website, the cookie categories and for individual settings, please refer to our
Cookie Settings.
The most effective way to do this is to disable cookies in your browser by consulting the Help section of your browser or taking a look at the
About Cookies website which offers guidance for all modern browsers.
2.1.6. Customer care
Depending on the subject matter of your request, we will rely on your personal data that has been stored within the scope of other data processing activities in our systems (e.g. data that you have provided during a purchase). If and to the extent that this is necessary to answer your query, we will also collect data from external sources (e.g. query with a shipping service provider as part of shipment tracking or an investigation request).
In context of requests concerning a (pre)contractual relationship with you, this data processing is necessary for the performance of a contract (provision of a customer service) with you. If you wish to exercise your rights with respect to us, the correspondent this data processing is necessary for compliance with a legal obligation. If you would like to receive information or complain about our products and services, the respective data processing is necessary for the purpose of our legitimate interest to respond to your information request / complaint.
2.2. Email marketing
2.2.1. Email newsletter dispatch to subscribers
If you have subscribed to our email newsletter we will send you newsletters from time to time to inform you about our products, services and promotions. This data processing is based on your consent.
Withdrawal of consent:
You can withdraw your consent and unsubscribe from our newsletter at any time by sending an email with your unsubscribe request to our customer (privacy@hipcampers.com) and/or by clicking on the unsubscribe link which is contained in every newsletter.
2.2.2. Direct marketing emails to existing customers
After the purchase of goods we may – regardless of whether you have subscribed to our newsletter – send you marketing emails for similar products and services. This data processing is based on our legitimate interest to advertise our products and services.
Objection to direct marketing emails:
You can object to this processing of personal data and unsubscribe from our direct marketing emails at any time by sending an email with your unsubscribe request to privacy@hipcampers.com and/or by clicking on the unsubscribe link which is contained in every direct marketing email.
2.3. Registration and setting up a customer account
When you visit our website, you can create a customer account. The registration for a customer account requires you to provide personal data. Mandatory fields are marked accordingly in the in-put form. This data processing is necessary for the performance of a contract (provision of a customer ac-count) with you.
2.4. Data processing in the case of orders in the online shop
We process your personal data in connection with the purchase of goods in our online shop.
2.4.1. Purchase and payment of goods in the online shop
We process your personal data (i.e. contact details, shipping and payment information) if you purchase goods in the online shop. If you purchase goods for another person (third party), we process the personal data of the third party provided by you (name and any contact details) for the dispatch of the goods to the third party. Please ensure that the third party has been sufficiently informed by you about the processing of their data at HIP Campers, and that you are authorised to provide such data. This data processing is necessary for the performance of a contract with you.
2.4.2. Shopping cart abandonment emails
If you have started an ordering process using your customer account, but have not concluded it, we will send you a reminder email to the email address stored in the customer account, regarding the purchasing process initiated by you. This data processing is necessary for the purpose of our legitimate interest to remind you of any purchasing processes that you have not yet completed.
Objection to shopping cart abandonment emails:
You can object to this processing of personal data and unsubscribe from our shopping cart abandonment emails at any time by sending an email with your unsubscribe request to privacy@hipcampers.com and/or by clicking on the unsubscribe link which is contained in every shopping cart abandonment email.
2.4.3. Fraud and credit check
Before concluding the purchase contract, we carry out a fraud and credit check. This is done to enable us to offer you a choice of different payment methods and at the same time to protect ourselves against the default of payment of the invoice. As part of the credit check, we check all previously made orders in your customer account. It is also checked whether the delivery address differs from the billing address, whether the delivery address is new or if the order should be delivered to a pack station. This data processing necessary for the purpose of our legitimate interest to avoid default of payment and fraud.
2.4.4. Cancellation of purchase
In any case of cancellation of the purchase (e.g. withdrawal of contract) we will process your personal data for returning the goods and refunding the purchase price. This data processing is necessary for the performance of a contract with you and/or for compliance with a legal obligation.
2.4.5. Invitation emails for product rating and review
We would like to know if you are satisfied with your purchased goods from us. For this purpose, we process your email and purchasing data (e.g. goods purchased and date of purchase), in order to send you an email within one month after the purchase, inviting you to rate and review your purchased product. This data processing is necessary for the purpose of our legitimate interest in good customer ser-vice and marketing.
Objection to product rating and review invitation emails:
You can object to this processing of personal data and unsubscribe from our product review and rating emails at any time by sending an email with your unsubscribe request to privacy@hipcampers.com and/or by clicking on the unsubscribe link which is contained in every product review and rating email.
2.4.6. Dunning process, collection and enforcement and/or defense of legal claims
In the case of outstanding amounts owed to us, we will advise you accordingly by email, SMS, letter or by phone, and under certain circumstances, will send you a dunning letter. If and to the extent that you still fail to make the payment, we will initiate a credit collection procedure.
The credit collection procedure will be carried out by a credit collection agency engaged by us. If necessary to carry out the credit collection procedure, the credit collection agency will carry out address enquiries, thereby availing itself of public registers in order to locate you as a debtor.
In the case of a legal dispute with you, we will process your personal data to enforce and/or defend our rights. If and to the extent necessary for the legal dispute, we will thereby rely also on data from other sources (e.g. public registers).
This data processing is necessary for the performance of a contract with you (Legal basis: Art. 6 (1) sentence 1, lit. b GDPR) as well as for the purpose of our legitimate interest in preventing the abuse of our services and in establishment and exercise of legal claims (Legal basis: Art. 6 (1) sentence 1, lit. f GDPR).
2.5. Other processing
2.5.1. Performance of internal audits
Within the scope of audits within HIP Campers, both at home and abroad, your personal data may be processed. During this process, we rely also on data from other sources, depending on the case (e.g. credit agencies).
Your data may, under certain circumstances, also be appropriately processed in order to identify and rectify misconduct within the enterprise, and to implement compliance programs and compliance measures.
2.5.2. Issuing of analyses
On the basis of your data, which we process the meaning of Section 2 of this Data Protection Information, we may issue analyses. These serve as a basis for our business decisions, to improve our products and services, to adapt to the needs of our customers and to carry out marketing activities. The analyses issued on this basis no longer have any personal reference, which means it is no long-er possible to trace them back to you. This data processing is necessary for the purpose of our legitimate interest to improve the products and services we offer and carry out marketing activities.
3. Retention and erasure of your personal data
We keep your personal data for as long and to the extent required for the purposes named in this Data Protection Information (Section 2).
As soon as the data for the purposes named in Section 2 is no longer required, we keep your personal data for the length of time, during which you can assert claims against us or we can assert claims against you (the statutory period of limitations is generally three years, starting with the end of the year in which the claim arises, e.g. the end of the year of purchase). In addition to this, we store your personal data for as long and to the extent we are obliged to do so by law. The retention periods may accordingly last up to ten years.
4. Transfer of personal data and the categories of recipients
Your personal data may be transferred / disclosed to the following categories of recipients:
- IT Service providers who prepare the platforms, databases and tools for our products and services (e.g. our website, the sale of goods, the dispatch of newsletters and in-formative emails), issue analyses on user habits on our websites, carry out marketing campaigns, and process your personal data during the purchasing process on our be-half.
- In connection with the use of Google Analytics and Google AdWords, including tags and cookies, your personal data may be transferred to the USA. In the case of the USA, the EU Commission has not decided that there is a suitable level of data protection within the meaning of the GDPR; such an adequacy decision (Art. 45 GDPR) has not been taken. Google LLC is, however, subject to the EU-U.S. Privacy Shield. This means that adequate protection of your personal data is guaranteed. You can retrieve the full text of the US Privacy Shield Framework at the following link:
https://www.privacyshield.gov/servlet/servlet.FileDownload?file=015t00000004qAg
- If you purchase products on our websites, we offer you various payment methods. In order to process a payment and, if necessary, a refund of the purchase price, we transfer your personal data, depending on the chosen payment method, to banks, payment service providers, financial service providers and credit card companies. The respective data transfers to such recipients are based on the performance of a contract with you.
- Should you be unable to meet your payment obligations, we transfer your personal data to collection agencies that carry out the collection procedure on our behalf. This transfer of personal data is necessary for the performance of a contract with you and for the purpose of our legitimate interest in an efficient accounts receivable management.
- For the delivery of your purchased products on our website (including notifications about the delivery status of the orders) we transfer your personal data to the fulfilment and shipping service providers (e.g. DHL, UPS, Speedy, etc.) engaged by us. The transfer of your personal data is based on the performances of a contract with you.
- In the case of legal disputes, we transfer your data to the competent court and, if you have engaged a lawyer, to the latter, in order to conduct the legal dispute. This transfer of personal data is necessary for compliance with a legal obligation and/or for the purpose of our legitimate interest in the establishment and exercise of legal claims.
- In addition to this, we only transfer your personal data if we are legally obliged to forward such data (e.g. to the police authorities within the scope of criminal investigations or to the data protection supervisory authorities). This transfer of personal data is necessary for compliance with a legal obligation.
5. Right to object to data processing based on legitimate interests
We process your personal data within the meaning of Section 2, based on our legitimate interest, in particular to guarantee IT security on our website, to adapt our website to your needs, to carry out analyses and marketing activities, to inform you about our products and services, to remind you of any purchasing processes that have not yet been completed, to increase the coverage of our products and marketing activities, to prevent fraud and abuse, to avoid payment defaults, to care for our customers, to safeguard, enforce and defend our legal interests (also before the courts, as necessary), and to carry out our internal management efficiently and collaboratively.
Notwithstanding the specific possibilities to object to data processing described in Section 2 (e.g. provided opt-out or unsubscribe links), you have the right to object at any time to the processing of your personal data on the basis of our legitimate interests pursuant to Art. 6 (1) sentence 1, lit. f GDPR on grounds relating to your particular situation by sending an email to privacy@hipcampers.com. We will then no longer process your data for this/these purpose(s) unless our legitimate interests in processing outweighs or the processing serves to establish, exercise or defend legal claims.
If you object to the processing of your data, we will process any collected personal data in this context in order to respond to your request. This data processing is necessary for compliance with a legal obligation.
6. Right to withdraw consent
If you have given us your consent for the processing of your personal data, you can withdraw this consent at any time. The withdrawal of your consent is effective for the future and shall not affect the lawfulness of processing based on consent before its withdrawal. Unless specifically regulated in Section 2, please send your withdrawal of consent to privacy-privacy@hipcampers.com. If you withdraw your consent, we process your personal data collected in this connection to answer your inquiry. This data processing is necessary for compliance with a legal obligation.
7. Your other data protection rights
In accordance with the GDPR, you may demand at any time that we:
- provide you with information on your personal data that we process (Art. 15 GDPR),
- rectify (Art. 16 GDPR),
- erase (Art. 17 GDPR),
- restrict (Art. 18 GDPR)
and/or
- export (Art. 20 GDPR)
your personal data stored on our systems.
Please send your request, stating at least your first and last name, either by email to privacy@hipcampers.com or in writing, to Pillar Ltd., 62 Shumako Street, 1434 Sofia, Bulgaria. If you exercise these rights against us, we will process your personal data in order to respond to your request. This data processing is necessary for compliance with a legal obligation.
8. Changes to this data protection information
The provisions of this Data Protection Information, including the referenced Cookie Information, shall apply in the version in force at the time the online shop is used. We reserve the right to supplement and modify the content of this Data Protection Information. The updated Data Protection Information applies from the time, in which it was published on our websites. In case of substantive or material changes to the Data Protection Information, especially changes that affect the processing of your personal data already collected by us, we will inform you in advance (e.g. by email).
9. Tracking pixels
You can view and edit your preferences about the ads shown to you across the web using Ads Settings in your browser. You may also set your browser to block all cookies, or opt out specific services here:
Self-Regulatory Program for Online Behavioral Advertising.