Xīn and Voltaire Limited
26-27 Bedford Square
London, WC1B 3HP, United Kingdom
1. Security and protection of your personal data when visiting our website
Xīn and Voltaire Limited (referred to hereafter as "Xīn and Voltaire " or "we") takes the protection of your personal data very seriously and uses extreme care and the most advanced security standards to guarantee it.
We consider it our overriding responsibility to safeguard the confidentiality of the personal data provided by you and to protect them from unauthorized access.
"Personal data" means any information relating to an identified or identifiable natural person (hereafter referred to as "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.
"Processing" means any operation or set of operations which is performed on personal data or on sets of personal data, whether by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
Restriction of processing
"Restrictions on processing" means the marking of stored personal data with the aim of limiting their processing in the future.
"Profiling” means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular, to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location, or movements.
"Pseudonymization" means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
"File system" means any structured set of personal data which are accessible according to specific criteria, whether centralized, decentralized or dispersed on a functional or geographical basis.
"Data controller" means the natural 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.
"Processor" means a natural or legal person, public authority, agency, or other body which processes personal data on behalf of the controller.
"Recipient" means a natural 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 inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.
"Third party" means a natural or legal person, public authority, agency, or body other than the data subject, controller, processor, and persons who, under the direct authority of the controller or processor, are authorized to process personal data.
"Consent" of the data subject means any freely given, specific, informed, and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
3. Lawfulness of processing
Processing shall be lawful only if there is a legal basis for processing data. Pursuant to Article 6 paragraph 1 points (a) – (f) GDPR such legal basis for processing data can be in particular:
- the data subject has given consent to the processing of his or her personal data for one or more specific purposes;
- processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;
- processing is necessary for compliance with a legal obligation to which the controller is subject;
- processing is necessary in order to protect the vital interests of the data subject or of another natural person;
- processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
- processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
4. Collection of personal data during a visit to our website
In case of a merely informative use of the website, i.e. if you do not register, buy something, or disclose to us data in other ways, we collect only those personal data which your browser transmits to our server. If you visit our website, we collect the data below which are technically necessary for us to show you our website and ensure its stability and security (the legal basis for this is Art. 6 paragraph 1 clause 1 point (f) GDPR):
- IP address
- Date and time of your inquiry
- Time zone difference to Greenwich Mean Time (GMT)
- Content of the request (actual page)
- Access status/HTTP status code
- Transmitted data volume
- Website from which the request is received
- Operating system and its interface
- Language and version of the browser software.
5. Information about the collection of personal data – (email, contact form, customer account and online shop)
(1) In what follows we inform you about the collection of your personal data when you use our website (contact form, customer account and online shop)
If you contact us by email, the data disclosed by you to us (email address, if necessary your name and your telephone number) are stored by us to allow us to answer your questions. We erase the data collected in this context after storage is no longer necessary or if the processing is restricted or of there exist legal retention obligations.
(3) If you buy products via our website or if you open a customer account for the administration of your current or future orders, we collect for this purpose the data that we need for the performance of the contract. These can be seen in the respective input fields for registration (customer account) or the purchase order form. When you place an order, we need as a minimum the obligatory data marked with a star (*). We use these data pursuant to Art. 6 paragraph 1 clause 1 point (b) GDPR for the performance of the contract and for handling your inquiries.
Our shop is hosted by Shopify Inc. Shopify offers us an e-commerce platform that allows us to sell our goods and services to you.
Your data are administered via data storage, a database and generally the Shopify app. Shopify stores your data on a secure server behind a firewall.
(4) Aside from payment by credit card, we offer also other payment methods for the use of our cybershop and for this purpose avail ourselves of various other payment service providers with whom we have signed third-party data processing agreements. We disclose different data to the various payment service providers depending on which payment method you have chosen. The legal basis for the disclosure is Art. 6 paragraph 1 clause 1 points (a), (b), (f) GDPR.
Here are our payment service providers:
If you pay for your purchases from us using PayPal, your personal data are disclosed to PayPal. If you have not yet opened a PayPal account, you will be asked by PayPal to do so in the course of the payment process. When using or opening a PayPal account, you must provide PayPal with, among other data, your name, address, telephone number and email address. The legal basis for the disclosure of the data is Article 6 paragraph 1 point (a) GDPR and Article 6 paragraph 1 clause 1 point (b) GDPR.
The operator of the PayPal payment service is:
PayPal (Europe) S.à r.l. et Cie, S.C.A.
22-24 Boulevard Royal
The use of one of our AfterPay payment methods is offered to you by
Arvato Payment Solutions GmbH
Gütersloher Str. 123
(hereafter: AfterPay). As data controller under the General Data Protection Regulation within the meaning of Regulation (EU) 2016/679 ("GDPR") it is responsible for the storage and processing of your personal data collected from you in the context of its services as well as for compliance with the applicable rules and regulations.
If you place an order on the website and want to use one of our AfterPay payment methods or if you wish to contact us in the context of the payment process, AfterPay will collect the following information about you (either directly from you or via us):
- Information about the goods and services, such as information about the ordered articles (e.g. the purchase order value, product group, merchandise value, if necessary the source of the inquiry and delivery mode)
- Financial information such as your income, any credit obligations, notes about a negative payment history
- Historical information such as information about the progress of your order, the payment process and past creditworthiness
- Information about the interaction between you and AfterPay, such as the way you used the services, including information about unpaid and current liabilities and your (re-) payment history in case of AfterPay, your personal preferences as well as your interaction with the AfterPay customer service
- Information about the interaction between you and us, such as your communications with us, e.g. whether the goods were delivered
- IP address
- Device information ("User Agent")
AfterPay also might carry out an identity and creditworthiness check. In this process the data provided by you for the purchase are compared with the existing data of a credit rating agency. These data are processed based on an explicit consent granted by you, the legal basis being Art. 6 para. 1 clause 1 point (a) GDPR. In accordance with Art. 7 para. 3 GDPR you may withdraw the granted consent effective for the future at any time and for any reason.
If you use the payment processing by our payment service provider
Clearpay Finance Limited
22 Long Acre
(hereafter: Clearpay), Clearpay will process the following personal data:
- Contact information such as name, address, telephone number, email, and other similar information.
- Payment information such as credit card numbers linked to your Clearpay account or transmitted by you to Clearpay.
- Other personal information such as date of birth, driver's license number or other identification information or documents.
Clearpay also might carry out an identity and creditworthiness check. In this process the data provided by you for the purchase are compared with the existing data of a credit rating agency. These data are processed based on an explicit consent granted by you, the legal principle being Art. 6 para. 1 clause 1 point (a) GDPR. In accordance with Art. 7 para. 3 GDPR you may withdraw the granted consent effective for the future at any time and for any reason.
On our website we offer payment via Stripe and the associated payment methods. The provider of this payment service is
Stripe Payments Europe Ltd
The One Building
Lower Grand Canal St
If you choose payment via Stripe, the payment data entered by you are disclosed to Stripe. The disclosure of your data to Stripe takes place on the basis of Art. 6 para. 1 clause 1 point (a) GDPR (consent) and Art. 6 para. 1 clause 1 point (b) GDPR (processing for the performance of a contract). You have the option to withdraw your consent to the data processing at any time. A withdrawal does not affect the validity of past data processing operations. All data necessary for payment processing will be used exclusively for the execution of the payments and transmitted following "SSL" procedures.
Stripe also might carry out an identity and creditworthiness check. In this process the data provided by you for the purchase are compared with the existing data of a credit rating agency. These data are processed based on an explicit consent granted by you, the legal principle being Art. 6 para. 1 clause 1 point (a) GDPR. In accordance with Art. 7 para. 3 GDPR you may withdraw the granted consent effective for the future at any time and for any reason.
(5) We will disclose your contact data also to the responsible shipper if this is necessary for processing your order (here: delivery of the merchandise).
(6) Based on the rules and regulations of commercial and fiscal law we are obligated to store your address as well as your payment and order data for the duration of ten years. However, we restrict processing after two years, i.e. your data will be used only in order to comply with legal obligations. The legal basis for this is Article 6 paragraph 1 clause 1 point (c) GDPR.
(1) With your consent you may subscribe to our Newsletter in which we inform you about our current special offers. The promoted goods and services are described in the declaration of consent. The legal basis is Art. 6 paragraph 1 clause 1 point (a) GDPR.
(2) We use the so-called double-opt-in procedure for the application to our Newsletter, meaning that following your application we send you an email to the indicated email address in which we ask you to confirm that you requested a subscription to the Newsletter. If you do not confirm your application within 24 hours, your information will be blocked and erased automatically after one month. In addition, we store the IP addresses you used and the time of your application and confirmation. The purpose is to have proof of your application and if necessary to be able to clarify a possible misuse of your personal data.
(3) The only obligatory information for the subscription to our Newsletter is your email address. The provision of additional, separately marked data is voluntary and is used in addressing you personally. After your confirmation, we store your email address for the purpose of sending you the Newsletter.
(4) You may withdraw your consent to the subscription of the Newsletter at any time and you may cancel the Newsletter at any time. You may confirm the withdrawal by clicking on the link provided in each e-mailed Newsletter or by sending a message to the contact data indicated in the imprint.
(5) We use the external service provider Klayvio as third-party processor for sending the Newsletter. We signed a separate third-party processing contract with the service provider in order to ensure the protection of your personal data. Further information about Klayvio is available on the website https://klayvio.com/.
7. Use of external tools on our website
We have integrated various tools from different companies with our website which allow us to analyse user behaviour or establish links with other websites.
For this purpose we work with the following service providers:
The third-party data processor has integrated the component Google Analytics on this website (with an anonymization function).
Google Analytics is a website analysis service. Website analysis refers to the collection, recording and analysis of data regarding the behaviour of visitors to the website. A website analysis service records e.g. data showing from which website a data subject has come to a website (the so-called referrer), which subpages of the website were accessed or how often and how long a subpage was viewed. Website analysis is used mainly for the optimization of a website and for a cost-benefit analysis of Internet adverting.
Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA, is the operator of the Google Analytics component.
However, when you by activate IP anonymization on our website, Google shortens your IP address within the Member States of the European Union or in other countries that are parties to the European Marketing Area Treaty. Only in exceptional cases is the full IP address transmitted to a Google server in the USA and shortened there. Google uses this information to analyse your use of the website in order to compile a report about your website activities and provide us with other services associated with your website and Internet use. The IP address of your browser transmitted by Google Analytics is not linked to any other Google data.
This website also uses the UserID functions of Analytics to be able to track interaction data. This User ID is also anonymized and encrypted and is not linked to other data.
You may prevent the storage of cookies by setting your browser software accordingly, but you might then not be able to fully use all functions of our website.
You may furthermore prevent the disclosure of the data generated by the cookie which refer to the use of the website (incl. your IP address) to Google as well as the processing of these data by Google by downloading and installing the browser plug-in available under the following link: https://tools.google.com/dlpage/gaoptout?hl=en.
Besides, a cookie left behind by Google Analytics may be erased at any time via the Internet browser or other software programs.
Our website also uses Google Analytics performance reports by demographic factors and interests as well as reports about impressions in the Google Display Network. You may deactivate Google Analytics for display advertising and set the displays in the Google Display Network by accessing the display settings under this link: https://www.google.de/ads/preferences?ac_tld=de&continue=aHR0cHM6Ly9hZHNzZXR0aW5ncy5nb29nbGUuZGUvYW5vbnltb3Vz.
Google Tag Manager
This website uses Google Tag Manager. This service allows you to administer so-called website tags centrally via an interface. Google Tag Manager implements only tags. No cookies are used and no personal data are collected.
However Google Tag Manager does not access these data. If certain domains/websites or cookies were deactivated, it remains in place for all tracking tags provided that they are implemented using Google Tag Manager.
Facebook Tracking Pixel
With your consent we will use Facebook's "tracking pixel". With the help of this pixel the behavior of users can be tracked once they are linked by click to a Facebook or Instagram ad on our website. This allows us to record the effectiveness of the Facebook and Instagram ads for statistical and market research purposes and to take optimization measures if necessary. Users who clicked on a Facebook or Instagram ad on our website may be tracked for up to 180 days.
The data recorded in such manner are anonymous for us, i.e. we do not see the personal data of the individual users. These data are however stored and processed by Facebook, which we will bring to your attention as we become aware of it.
Facebook may link these data with the Facebook account and use them also for its own advertising purposes according to its own data use guidelines.
If you prefer to deactivate the cookie storage on behalf of Facebook, you may do so by adjusting your browser settings accordingly.
Facebook Communications Tools
We also use Facebook's Communications Tools, in particular the product "Custom Audiences" and "Website Custom Audiences". In principle this generates a non-reversible and non-personal checksum (hash value) of your user data which may be transmitted to Facebook for analysis and marketing purposes.
If you wish to object to the use of Facebook's Website Custom Audiences, you may do so under https://www.facebook.com/settings/?tab=ads.
In addition we use Customer Match Lists in the context of our Facebook advertising activities, e.g. for "Lookalike Audiences" and remarketing. For the use of Customer Match, lists with encrypted user data are uploaded to Facebook. After uploading the data, the system checks which data are already known and assigns the users to a list. After the preparation of the Customer Match List the encrypted customer data are again automatically erased. Facebook does not obtain any new addresses in this process (encryption).
We store this information for the duration of 12 months.
This data processing is based on the principles of Art. 6 paragraph 1 point (f) GDPR for the protection of our legitimate interests, i.e. the optimization of our offer.
session_id, proprietary token, session-related, allowing Shopify to store information about your session (referrer, target website, etc.).
shopify_visit, no data storage, lasting for 30 minutes from your last visit, is used by the internal statistics tracker of our website provider to track the number of visitors.
shopify_uniq, no data storage, expires at midnight (relative to the visitor) of the next day, counts the number of shop visits by individual customers.
cart, proprietary token, lasting for 3 weeks, stores information about the content of your shopping cart.
secure_session_id, proprietary token, session-related
storefront_digest, proprietary token, unlimited duration, used if the shop has a password in order to determine whether the current customer has access.
9.Your privacy rights vis-à-vis Xīn and Voltaire
(1) Ability to withdraw your consent, Article 7 GDPR
(2) Right of access to information, Article 15 GDPR
Pursuant to Article 15 paragraph 1 GDPR you have the right to know whether we process your personal data. If we do, you have a right to additional information (Article 15 paragraph 2 GDPR).
(3) Right to rectification, erasure or restriction of processing, Article 16, 17 and 18 GDPR
Under Article 16 GDPR you have the right to demand the immediate rectification of inaccurate personal data and the completion of incomplete data, including by means of a supplementary statement.
In particular, pursuant to Article 17 GDPR you have the right to demand the erasure of personal data concerning yourself if the processing of your personal data is not or no longer permitted.
(4) Right to object, Article 21 GDPR
Under Article 6 paragraph 1 (e) or (f) GDPR you have the right to object at any time to the processing of your personal data on grounds relating to your situation; this applies also to any profiling based on these provisions. We will then no longer process your data unless we demonstrate compelling legitimate grounds for such processing which override your own interests, rights, and freedoms.
You may exercise the right to object at any time by contacting us via the contact options specified in the imprint.
(5) Right to lodge a complaint with a supervisory authority, Article 77 GDPR
Without prejudice of another administrative or judicial remedy, you also have the right to lodge a complaint with a supervisory authority, in the Member State of your place of residence, your job or the place of the presumed violation if you believe that the processing of your respective personal data is unlawful. The data protection agency of the Republic of Austria provides forms for the exercise of your legal rights and for a complaint under https://www.dsb.gv.at/download-links/dokumente.html. For our European customers: Your competent supervisory authority is that of your residence. A list of all supervisory authorities can be found under https://edpb.europa.eu/about-edpb/about-edpb/members_en
For questions about the collection, processing or use of your personal data, or for information about, correction, restriction, or erasure of data as well as the withdrawal of a consent granted by you or an objection to a particular data use, please contact us directly using the contact data in our imprint.
Status of the privacy and data security policy: October 11, 2022