PRIVACY POLICY - January 2026

Data Protection Officer (DPO):

Christian Kernchen e. K.
Joergstr. 31 | D-80689 Munich

Tel.: +49 89 289 747 35
Fax.: +49 89 289 747 36

E-Mail: privacy (at) froosty (dot) com
Website: www.froosty.com

Registered Court: Amtsgericht Munich
Registration Number: HRA 96743

VAT Number § 27a UStG: DE 275199715

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 inform you about the handling of your personal data when using 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 Christian Kernchen e. K., Joergstr. 31, 80689 Munich, Germany, phone: +49 89 289 747 35, fax: +49 89 289 747 36, email: contact (at) froosty (dot) com. 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 the processing of personal data.

1.3 The person responsible has appointed a data protection officer who can be reached as follows: "Christian Kernchen e. K., Joergstr. 31, 80689 Munich, Tel.: +49 89 289 747 35, email: privacy (at) froosty (dot) com"

1.4 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 an 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 only use our website for informational 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 visit our website, we collect the following data that is technically necessary for us to display the website to you:

- Our visited website
- Date and time at the time of access
- Amount of data sent in bytes
- Source/reference from which you came to the page
- Browser used
- Operating system used
- IP address used (if necessary: in anonymous form)

The processing takes place in accordance with Article 6 Paragraph 1 Letter 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) Hosting & Content Delivery Network

3.1 Hosted by Shopify

We use the shop system of the service provider Shopify International Limited, Victoria Buildings, 2nd floor, 1-2 Haddington Road, Dublin 4, D04 XN32, Ireland ("Shopify") for the purpose of hosting and displaying the online shop on the basis of a processing on our behalf. All data collected on our website is processed on Shopify's servers. As part of the aforementioned Shopify services, data may also be processed as part of further processing on behalf of Shopify Inc., 150 Elgin St, Ottawa, ON K2P 1L4, Canada, Shopify Data Processing (USA) Inc., Shopify Payments (USA) Inc. or Shopify (USA) Inc. In the case of the transmission of data to Shopify Inc. in Canada, the appropriate level of data protection is guaranteed by the European Commission's adequacy decision. Further information on Shopify's data protection is available on the following website: https://www.shopify.de/legal/datenschutz
Further processing on servers other than those of Shopify mentioned above only takes place within the scope communicated below.

3.2 Cloud Flare

On our website we use a so-called Content Delivery Network ("CDN") from the technology service provider Cloudflare Inc., 101 Townsend St. San Francisco, CA 94107, USA ("Cloudflare"). A content delivery network is an online service that is used to deliver large media files (e.g. graphics, page content or scripts) through a network of regionally distributed servers connected via the Internet. Using Cloudflare's Content Delivery Network helps us to optimize our website's loading speeds.

Processing is carried out in accordance with Article 6 Paragraph 1 Letter f GDPR on the basis of our legitimate interest in providing our website securely and efficiently, and improving the stability and functionality of our website.
We have concluded an order processing agreement (Data Processing Addendum, available at https://www.cloudflare.com/media/pdf/cloudflare-customer-dpa.pdf) with Cloudflare, which obliges Cloudflare to protect the data of our site visitors and not to pass them on to third parties. For the transmission of data from the EU to the USA, Cloudflare relies on so-called standard data protection clauses of the European Commission, which is intended to ensure compliance with the European level of data protection in the USA.

For more information, see Cloudflare's privacy policy at: https://www.cloudflare.com/privacypolicy/

3.3 Fastly

On our website we use a so-called Content Delivery Network ("CDN") from the technology service provider Fastly Inc., 475 Brannan St. #300, San Francisco, CA 94107, USA ("Fastly"). A content delivery network is an online service that is used to deliver large media files (e.g. graphics, page content or scripts) through a network of regionally distributed servers connected via the Internet. Using Fastly's Content Delivery Network helps us to optimize our website's loading speeds.
Processing is carried out in accordance with Article 6 Paragraph 1 Letter f GDPR on the basis of our legitimate interest in providing our website securely and efficiently, and improving the stability and functionality of our website. For more information, see Fastly's privacy policy at: https://www.fastly.com/privacy

4) Cookies

In order to make visiting our website attractive and to enable the use of certain functions, we use cookies, i.e. small text files that are stored on your end device. Some of these cookies are automatically deleted after closing the browser (so-called “session cookies”), some of these cookies remain on your end device for a longer period of time and enable page settings to be saved (so-called “persistent cookies”). In the latter case, you can find the storage period in the overview of the cookie settings in your web browser.

If personal data is also processed by individual cookies used by us, the processing takes place in accordance with Article 6 (1) (b) GDPR either for the execution of the contract, in accordance with Article 6 (1) (a) GDPR in the event that consent has been given or in accordance with Art. 6 (1) (f) GDPR to protect our legitimate interests in the best possible functionality of the website and a customer-friendly and effective design of the site visit.

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 for certain cases or in general.

Each browser differs in the way it manages the cookie settings. This is described in the help menu of each browser, which explains how you can change your cookie settings. You will find these for the respective browsers under the following links:

- Internet Explorer: https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies

- Firefox: https://www.mozilla.org/en-US/privacy/websites/#cookies

- Chrome: https://support.google.com/accounts/answer/61416?co=GENIE.Platform%3DDesktop&hl=en

- Safari: https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac

- Opera: https://help.opera.com/en/latest/web-preferences/#cookies

Please note that if cookies are not accepted, the functionality of our website may be restricted.

17) Contact

If you contact us by e-mail, the information you provide will be stored for the purpose of processing the request and for possible follow-up questions.

18) Right of Information, correction, Blocking and deletion

We adhere to the principles of data avoidance and data economy. We therefore only store your personal data for as long as is necessary to achieve the purposes stated here or as provided for by the various storage periods provided for by the legislature. After the respective purpose has ceased to exist or these periods have expired, the corresponding data will be blocked or deleted as a matter of routine and in accordance with the statutory provisions. You have the right to receive information about your personal data stored by us, its origin and recipient and the purpose of the data processing at any time. You also have the right to have your personal data corrected, blocked or deleted.

Please contact the data protection officer:
Christian Kernchen e. K. – Email: privacy (at) froosty (dot) com

19) Right of Object

If your personal data is processed on the basis of legitimate interests in accordance with Article 6 Paragraph 1 Sentence 1 lit. f GDPR, you have the right to object to the processing of your personal data in accordance with Article 21 GDPR, provided there are reasons for this, which arise from your particular situation or the objection is directed against direct advertising. In the latter case, you have a general right of objection, which we will implement without specifying a particular situation.

If you would like to make use of your right of cancellation or objection, it is sufficient to send an email to:

Christian Kernchen e. K. – Email: privacy (at) froosty (dot) com

20) Question to the Data Protection Officer

If you have any questions about data protection, please contact our data protection officer directly:

Christian Kernchen e. K. – Email: privacy (at) froosty (dot) com

- IT-Recht-Kanzlei - Alter Messeplatz 2 - 80339 München
www.it-recht-kanzlei.de

- Christian Kernchen e.K. | FROOSTY - Joergstr. 31 - 80689 München
www.froosty.com | contact (at) froosty (dot) com