Data Protection Statement

(May 28, 2018)

Charles Simmons
Steinstrasse 24
70794 Filderstadt

Tel: +49 (0)160 – 93 83 04 39

The protection of your personal data is of particular concern to us. Therefore, we comply with the legal requirements when we collect and process your personal data. Below you will find extensive information about the scope and purpose of collecting data.

Principle of anonymous data use

In principle, our offers can be used without providing personal data. The use of individual services on our website can, therefore, entail divergent regulations which in this case are explained separately below. The legal basis for data protection can be found in the General Data Protection Regulation (GDPR).

When you access our website or Apps, some information, such as IP address, is transferred. You are also providing information about the end device used (computer, smartphone, tablet etc.), the browser used (Internet Explorer, Safari, Firefox, Chrome, etc.), time of visit to the website, the so-called referrer, and volume of data transferred.

We cannot use this data to identify an individual user. We only use this information to determine how attractive our offers are and to improve their performance or content, if necessary, and make their design even more appealing to you.

Please bear in mind, however, that in the case of a static IP address, personal identification is possible by RIPE query in individual cases, although we do not perform this. Nevertheless, this website is accessible for both static and dynamic IP addresses assigned.

Collection and processing of personal data

We only collect personal data if you provide it to us, for example when you contact us, placing an order or requesting information.

We use the personal data you provide only to the extent that your data is necessary for rendering or processing our services.

We store your data for as long as is necessary to achieve the intended purpose or until you delete your account or for as long as legal retention periods require data to be stored. Your data is subsequently deleted in accordance with legal requirements or processing is restricted.

In the case of use purely for information, i.e. if you do not register or send us information another way, we only collect personal data which your browser transfers to our servers. If you want to view our website, we collect the following data, which we require for technical purposes in order to show you our content and guarantee stability and security (legal basis is a legitimate interest pursuant to Article 6 (1) (f) GDPR).

In the context of the balance of interests in accordance with Article 6 (1) (f) GDPR, we have considered and weighed up our interest in website provision and your interest in data protection compliant processing of your personal data. As the data below is technically required for the provision of our service in order to offer you our website and also guarantee stability and security, in particular, protection against misuse, we have reached the conclusion that, with a state-of-the-art oriented data security guarantee, this data can be processed whereby appropriate consideration will be given to your interest in data protection compliant processing.

Data Purpose of processing Maximum storage time
Operating system used Evaluation by devices to ensure optimized presentation of the website For an indefinite period
Information about the browser type and version used Evaluation of the browsers used to optimize our websites for this purpose For an indefinite period
IP address Display of the website on the respective device

Investigation and prevention of fraud cases

Proof of the user’s consent to the newsletter dispatch

For an indefinite period
Date and time of the request Display of the website on the respective device

Investigation and prevention of fraud cases

Proof of the user’s consent to the newsletter dispatch

For an indefinite period
If applicable, manufacturer and type designation of the smartphone, tablet or other end devices Evaluation of device manufacturers and types of mobile devices for statistical purposes For an indefinite period


The collection of data for website provision and the storage of data in log files is imperative for website operation. Consequently, users may not object to this.

Registration of an Account

Through our login system, you can create an account which allows you access to your chosen membership package, as well as the possibility to upgrade to a different membership package. We use cookies – small data files – in your browser to identify you. All data you enter in your account is stored in a database of Charles Simmons, Steinstrasse 24, 70794 Filderstadt. We ask for the data mentioned below when registering (partially obligatory). You must also read and accept our Privacy Policy and Terms and Conditions.

Data Purpose of processing Legal basis of the processing Maximum storage time
First name Direct approach & presentation Implementation of the contractual relationship Up to 30 days after deletion of the customer account
Last name Direct approach & presentation Implementation of the contractual relationship Up to 30 days after deletion of the customer account
Email Address Customer account identification Implementation of the contractual relationship Up to 30 days after deletion of the customer account
Password Customer account identification Implementation of the contractual relationship Up to 30 days after deletion of the customer account
IP address at login Data transfer at registration to web server Implementation of the contractual relationship For an indefinite period


All other requested information (address, city, country, zip code) is optional and is not required to open an account.

Data collection, processing and use in the context of our services

Cookies and tracking pixels

We use cookies to improve our web service and make your use as easy as possible. Cookies are small text files which are saved on your computer when you visit our website. They facilitate the repeated allocation of your browser. Cookies save information, such as your language settings, the duration of the visit to our website or the entries you made there. This means that the required data does not need to be entered again each time the service is used. Moreover, cookies help us to recognize your preferences and adjust our website to your areas of interest.

Most browsers accept cookies automatically. If you want to prevent cookies from being saved, you can select the ‘Accept no cookies’ option in your browser settings. To find out exactly how this works, you can consult your browser manufacturer’s instructions. You can delete cookies that have already been saved on your computer at any time. Please bear in mind, however, that our website service can only be used to a limited extent without cookies.

Moreover, every time our website is loaded, we record how often it is visited and clicked on by using tags on our website, so-called tracking pixels, likewise without any interference and intervention for your computer.

Strato Analytics

We use the Strato Analytics service from our internet service provider Strato AG (STRATO AG, Pascalstraße 10, 10587 Berlin) to analyze our website visitors. The user data gathered is for informational purposes only and no private user data is stored on Strato servers.

Social Plugins

This website uses social plugins from third-party providers.

  • Facebook (Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA)

By default, these plugins usually collect data from you and transmit it to the servers of the respective provider.

The plugins also collect personal data, such as your IP address, sending this data to the servers of the respective provider where it is stored. Additionally, activated social plugins set a cookie with a unique identifier to allow providers to create profiles of your usage behavior. This occurs even if you are not a member of the social network of the respective provider. If you are a member of the social network of the provider and you are logged in to the social network while visiting the Freeletics website, your data and information about your visit to this website can be linked to your profile on the social network. We have no influence on the exact extent of the data collected from you by the respective provider. For more information about the scope, type and purpose of data processing, and about rights and setting options for the protection of your privacy, please refer to the data protection information of the respective provider of the social network. These can be found in the above table and you may access them directly at the following links:

Transfer of data to third parties

We only pass your personal data on to third parties if:

  • you have given your explicit consent to this,
  • forwarding data is necessary for the assertion, exercise or defense of legal claims and there is no reason to assume you have an overriding legitimate interest in your data not being passed on,
  • in the event that we have a legal obligation to forward data, and
  • this is legally permissible and required for the performance of the contractual relationship with you.

In the case of data transfer outside the European Union, the high European level of data protection essentially does not exist. It may be the case with a transfer that an EU Commission adequacy decision in accordance with Article 45 (1) (3) GDPR is not currently in place. This means the EU Commission has not yet decided that the level of data protection in the respective country corresponds to the level of protection in the European Union based on the GDPR. Consequently, we have put the appropriate guarantees referred to above in place. Potential risks, which cannot be ruled out completely in connection with data transfer, are in particular:

  • your personal data could be processed over and above the intended purpose.
  • Moreover, there is a possibility that you may not be able to exercise your rights in relation to data protection, for example your right of access, to rectification, erasure or data portability, on a consistent basis and enforce these.
  • It may also be highly likely that data is processed incorrectly and in quantitative and qualitative terms, the protection of personal data fails to meet the requirements of the GDPR in full.

Your rights

Information on the rights of data subjects

Each data subject has the right of access in accordance with Article 15 GDPR, the right to rectification in accordance with Article 16 GDPR, the right to erasure in accordance with Article 17 GDPR, the right to restriction of processing in accordance with Article 18 GDPR, the right to object in Article 21 GDPR and the right to data portability in Article 20 GDPR. The limitations according to Articles 34 and 35 BDSG apply to the right of access and to the right to erasure.

Information on the option to lodge a complaint

You also have the right to lodge a complaint with the competent data protection authority about our processing of your personal data.

Information on withdrawal of consent

You can withdraw your consent with us to process personal data at any time. This also applies to withdrawals of a declaration of consent that were given to us before the General Data Protection Regulation came into effect, i.e. before May 25, 2018. Please note that this withdrawal will only apply prospectively. This does not affect processing that took place prior to a withdrawal.

Right in the event that data is processed for direct marketing purposes

You have the right pursuant to Article 21 (2) GDPR to object to the processing of personal data concerning you. In the event that you object to processing for direct marketing purposes, we will no longer process your personal data for this purpose. Please note that this withdrawal will only apply prospectively. This does not affect processing that took place prior to a withdrawal.

Information on the right to object in the case of balance of interests

If we process your personal data based on a balance of interests, you can object to such processing. If you exercise this right to object, please state the reasons why we should not process your data as we have described. If your objection is justified, we will review the situation and either stop or adjust data processing or explain our compelling legitimate reasons for processing to you.

Links to other websites

Our website may contain links to the websites of other providers. Please note that this Data Privacy Statement applies only to the website of ALVIN MILLS.  We have no influence on or control over the compliance of other providers with applicable data protection regulations.

Amendments to the Data Privacy Statement

We reserve the right to amend or adjust this Data Privacy Statement at any time subject to compliance with applicable data protection regulations.

Controller and data protection officer

Alternatively, you may contact Charles Simmons at any time if you have any questions regarding the collection, processing or use of your personal data or in the case of access, rectification, blocking or erasure.


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