PRIVACY POLICY

This privacy policy informs you about the processing of personal data when visiting our websites www.broadway-fashion.com and www.my-broadway.com (hereinafter referred to as “Website”).

Protecting your data is important to us. We process your personal data solely in accordance with legal regulations, in particular the General Data Protection Regulation (GDPR), the Federal Data Protection Act (BDSG), and the Telecommunications Telemedia Data Protection Act (TTDSG).

1. Controller

Broadway Fashion GmbH
Modering 5
22457 Hamburg
Germany

Email: datenschutz@broadway-fashion.com

2. Data Protection Officer

If you have any questions about data protection, please contact our Data Protection Officer:

Email: datenschutz@broadway-fashion.com

3. General Information on Data Processing

We only process users’ personal data to the extent necessary for the operation of a functional website and for providing our content and services. Processing is based on legal permissions or your explicit consent.

4. Legal Basis for Processing

We process your data on the following legal bases:

Art. 6(1)(a) GDPR – Consent

Art. 6(1)(b) GDPR – Contract performance or pre-contractual measures

Art. 6(1)(f) GDPR – Legitimate interests, provided your interests do not override ours

Art. 49(1) GDPR – Data transfer to third countries without adequacy decision (e.g., USA)

5. Hosting & Infrastructure

Our website is hosted by an external service provider. The following data is automatically processed:

IP address

Date and time of access

Browser type and version

Referrer URL

Visited pages

Transferred data volumes

This processing ensures the stability, functionality, and security of the website.

Legal basis: Art. 6(1)(f) GDPR (legitimate interest)

Storage duration: Log files are deleted after 30 days, unless relevant to security.

6. Content Delivery & Security via Cloudflare

To secure our website and improve loading times, we use the CDN and security service Cloudflare, provided by:

Cloudflare Inc., 101 Townsend St., San Francisco, CA 94107, USA.

Your IP address may be processed by Cloudflare and transferred to the USA.

Legal basis: Art. 6(1)(f) GDPR

Third-country transfer: Cloudflare is certified under the EU-U.S. Data Privacy Framework (DPF)

https://www.dataprivacyframework.gov/

7. Use of Cookies & Consent Management

We use cookies and similar technologies to provide certain functionalities and analyze user behavior.

Consent is managed via the tool CCM19 (Papoo Software & Media GmbH, Bonn). Upon first visit, you can choose via the cookie banner whether to allow non-essential cookies (e.g., for statistics or marketing).

Cookie Categories:

Essential cookies – required for technical functionality (no consent required)

Statistics cookies – e.g., Matomo, Google Analytics

External services – e.g., Google Maps

Consent may be withdrawn or adjusted at any time.

Legal basis: Art. 6(1)(a) GDPR in conjunction with § 25 TTDSG

8. Web Analytics with Matomo (Locally Hosted)

We use the open-source tool Matomo to analyze user behavior. The processing takes place anonymously on our own servers (no third-party access, no international data transfers).

IP addresses are anonymized before storage

No user profiles

No third-party cookies

Legal basis: Art. 6(1)(a) GDPR (only with consent via CCM19)

Data transfer: None

9. Web Analytics with Google Analytics

We also use Google Analytics, provided by:

Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

Cookies are set and usage data transferred to Google servers in the USA.

Third-country transfer: Google is certified under the EU-U.S. Data Privacy Framework.

More info: https://policies.google.com/privacy/frameworks

Legal basis: Art. 6(1)(a) GDPR in conjunction with § 25(1) TTDSG (consent via CCM19)

Withdrawal: possible anytime via cookie settings

10. Google Maps

We use Google Maps to display locations. Provider: Google LLC, USA. The service is only loaded after active consent via the cookie banner.

Processed data: IP address, location data (if enabled), technical metadata

Legal basis: Art. 6(1)(a) GDPR

Third-country transfer: Google is DPF certified

11. Contractual Data Processing (e.g., Orders)

When placing orders through our website, the following personal data is processed:

Name, address

Email address

Payment and order data

These are required for processing, shipping, and invoicing.

Legal basis: Art. 6(1)(b) GDPR

Storage: Deleted after statutory retention periods (e.g., tax, commercial law)

12. Your Rights

You have the following rights as a data subject:

Access (Art. 15 GDPR)

Rectification (Art. 16 GDPR)

Erasure (Art. 17 GDPR)

Restriction (Art. 18 GDPR)

Data portability (Art. 20 GDPR)

Objection (Art. 21 GDPR)

Withdrawal of consent (Art. 7(3) GDPR)

Contact: datenschutz@broadway-fashion.com

13. Duration of Storage

We store personal data only as long as required for its purpose or statutory obligations. Once the purpose is fulfilled or retention periods expire, the data is deleted.

14. Data Sharing and Third-Country Transfers

Data is only shared if:

Required for contract execution

You have provided consent

There is a legal obligation

Third-country transfers only occur with Google and Cloudflare (both DPF certified).

15. Data Security

We apply technical and organizational security measures (Art. 32 GDPR) to protect your data against loss, destruction, or unauthorized access. Transmission is SSL-encrypted.

16. Supervisory Authority

You have the right to lodge a complaint with a supervisory authority:

Hamburg Commissioner for Data Protection and Freedom of Information

Ludwig-Erhard-Str. 22, 20459 Hamburg

Web: https://datenschutz-hamburg.de

17. Amendments to this Privacy Policy

We may update this policy to reflect legal changes or adjustments to our services.

Effective date of this privacy policy: July 2025