Privacy Policy

Preamble

With the following privacy policy we would like to inform you about which types of your personal data
(hereinafter also referred to simply as “data”) we process, for which purposes and to what extent.
This privacy policy applies to all processing of personal data carried out by us, both in the context
of providing our services and in particular on our website, in mobile applications and within external
online presences, such as our social media profiles (hereinafter collectively referred to as the
“online offering”).

The terms used are not gender-specific.

Status: 15 November 2025

Table of Contents

• Preamble

• Controller

• Overview of Processing

• Relevant Legal Bases

• Security Measures

• Transfer of Personal Data

• General Information on Data Storage and Deletion

• Rights of Data Subjects

• Business Services

• Provision of the Online Offering and Web Hosting

• Use of Cookies

• Contact and Enquiry Management

• Presence in Social Networks (Social Media)

• Changes and Updates

Controller

Marc Nahry
Hertogstraat 19
6828ER Arnhem

E-mail:

info@clumsy-rings.com

Overview of Processing

The following overview summarises the types of data processed and the purposes of their processing
and refers to the categories of data subjects.

Types of Data Processed

• Inventory data

• Payment data

• Contact data

• Content data

• Contract data

• Usage data

• Meta, communication and process data

• Log data

Categories of Data Subjects

• Service recipients and clients

• Interested parties

• Communication partners

• Users

• Business and contractual partners

Purposes of Processing

• Performance of contractual services and fulfilment of contractual obligations

• Communication

• Security measures

• Reach measurement / audience measurement

• Office and organisational procedures

• Organisational and administrative procedures

• Firewall

• Feedback

• Provision of our online offering and user-friendliness

• Information technology infrastructure

• Public relations

• Business processes and business management procedures

Relevant Legal Bases

Relevant Legal Bases under the GDPR

Below you will find an overview of the legal bases of the GDPR on which we process personal data.
Please note that, in addition to the provisions of the GDPR, national data protection regulations may apply
in your or our country of residence or seat. If, in individual cases, more specific legal bases are relevant,
we will inform you of these in the privacy policy.

• Consent (Art. 6 (1) (a) GDPR) – The data subject has given consent to the processing
  of their personal data for one or more specific purposes.

• Performance of a contract and pre-contractual enquiries (Art. 6 (1) (b) GDPR) –
  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.

• Legal obligation (Art. 6 (1) (c) GDPR) – Processing is necessary for compliance
  with a legal obligation to which the controller is subject.

• Legitimate interests (Art. 6 (1) (f) GDPR) – 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.

National Data Protection Regulations in the Netherlands

In addition to the data protection provisions of the GDPR, national data protection rules apply in the
Netherlands. This includes in particular the “Uitvoeringswet Algemene verordening gegevensbescherming”
(UAVG – Implementation Act of the General Data Protection Regulation).

Security Measures

We take appropriate technical and organisational measures in accordance with the legal requirements,
taking into account the state of the art, implementation costs and the nature, scope, context and purposes
of processing as well as the varying likelihood and severity of risks to the rights and freedoms of natural
persons, in order to ensure a level of security appropriate to the risk.

These measures include, in particular, safeguarding the confidentiality, integrity and availability of data
by controlling physical and electronic access to the data as well as access, input, transfer, safeguarding
of availability and separation of the data. Furthermore, we have established procedures that ensure the
exercise of data subject rights, deletion of data and responses to threats to data. In addition, we take
the protection of personal data into account already during the development and selection of hardware,
software and processes, in accordance with the principles of data protection by design and by default.

IP address truncation:
Where IP addresses are processed by us or by the service providers and technologies used and the processing
of a full IP address is not necessary, the IP address is truncated (also referred to as “IP masking”).
In this process, the last two digits or the last part of the IP address after a dot are removed or replaced
by placeholders. Truncating the IP address is intended to prevent or significantly complicate the
identification of a person based on their IP address.

Securing online connections via TLS/SSL encryption technology (HTTPS):
In order to protect users’ data transmitted via our online services against unauthorised access, we use
TLS/SSL encryption technology. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the
cornerstones of secure data transmission on the internet. These technologies encrypt information transferred
between the website or app and the user’s browser (or between two servers), thereby protecting data from
unauthorised access. TLS, as the more advanced and secure version of SSL, ensures that all data transmissions
comply with the highest security standards. When a website is secured by an SSL/TLS certificate, this is
indicated by “HTTPS” in the URL, signalling to users that their data is being transmitted securely and in
encrypted form.

Transfer of Personal Data

In the course of processing personal data, it may happen that such data is transferred to other entities,
companies, legally independent organisational units or persons or disclosed to them. Recipients of this data
may include, for example, service providers commissioned with IT tasks or providers of services and content
that are integrated into a website. In such cases, we comply with the legal requirements and conclude,
in particular, appropriate contracts or agreements with the recipients of your data that serve to protect
your data.

General Information on Data Storage and Deletion

We delete personal data that we process in accordance with the legal provisions as soon as the underlying
consents are revoked or no further legal bases for processing exist. This covers cases where the original
processing purpose ceases to apply or the data is no longer needed. Exceptions apply where statutory
obligations or special interests require a longer retention or archiving period.

In particular, data that must be retained for commercial or tax law reasons or whose storage is necessary
for legal prosecution or for the protection of the rights of other natural or legal persons must be archived
accordingly.

Our privacy notices may contain additional information on the retention and deletion of data that applies
specifically to certain processing operations.

Where multiple retention periods or deletion deadlines are specified for a set of data, the longest period
is generally decisive. Data that is no longer required for the originally intended purpose but is retained
due to legal requirements or other reasons will only be processed for those reasons that justify its retention.

Beginning of retention periods at the end of the year:
If a retention period does not explicitly start on a specific date and is at least one year, it automatically
begins at the end of the calendar year in which the event triggering the period occurred. In the case of
ongoing contractual relationships under which data is stored, the triggering event is the date on which
termination takes effect or another ending of the legal relationship.

Rights of Data Subjects

Rights of Data Subjects under the GDPR

As a data subject, you have various rights under the GDPR, in particular arising from Articles 15 to 21 GDPR:

• Right to object: You have the right, on grounds relating to your particular situation,
  at any time to object to the processing of your personal data which is based on Article 6 (1) (e) or (f)
  GDPR, including profiling based on those provisions. Where your personal data is processed for direct
  marketing purposes, you have the right to object at any time to processing of personal data concerning
  you for such marketing; this also applies to profiling to the extent that it is related to such direct
  marketing.

• Right to withdraw consent: You have the right to withdraw consent you have given
  at any time.

• Right of access: You have the right to obtain confirmation as to whether or not
  personal data concerning you is being processed and, where that is the case, to access the personal
  data and further information and a copy of the data in accordance with the legal requirements.

• Right to rectification: In accordance with the legal requirements, you have the
  right to have inaccurate personal data concerning you rectified and incomplete data completed.

• Right to erasure and restriction of processing: In accordance with the legal
  requirements, you have the right to obtain the erasure of personal data concerning you without undue
  delay or, alternatively, to request restriction of processing of the data in accordance with the legal
  requirements.

• Right to data portability: You have the right to receive the personal data concerning
  you, which you have provided to us, in a structured, commonly used and machine-readable format and
  have the right to transmit those data to another controller, as far as this is technically feasible
  and in accordance with the legal requirements.

• Right to lodge a complaint with a supervisory authority: Without prejudice to any
  other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory
  authority, in particular in the Member State of your habitual residence, place of work or place of
  the alleged infringement, if you consider that the processing of personal data relating to you
  infringes the GDPR.

Business Services

We process the data of our contractual and business partners, e.g. customers and interested parties
(collectively referred to as “contractual partners”), in the context of contractual and comparable legal
relationships as well as associated measures and in the context of communication with the contractual
partners (or pre-contractually), e.g. in order to respond to enquiries.

We use this data to fulfil our contractual obligations. This includes, in particular, obligations to provide
the agreed services, any update obligations and assistance in remedying warranty and other performance issues.
In addition, we use the data to safeguard our rights and for administrative tasks and corporate organisation
associated with these obligations. Furthermore, we process the data on the basis of our legitimate interests
in proper and efficient business management and in security measures to protect our contractual partners and
our business operations from misuse, risks to their data, secrets, information and rights (e.g. by involving
telecommunications, transport and other auxiliary services, subcontractors, banks, tax and legal advisers,
payment service providers or tax authorities). In accordance with applicable law, we only disclose the data
of contractual partners to third parties to the extent that this is necessary for the aforementioned purposes
or to fulfil legal obligations. We inform contractual partners about other forms of processing, such as for
marketing purposes, within this privacy policy.

We indicate which data is required for the above purposes before or during data collection, e.g. in online
forms, by special markings (e.g. colours) or symbols (e.g. asterisks) or personally.

We delete the data after expiry of statutory warranty and comparable obligations, i.e. generally after four
years, unless the data is stored in a customer account, for example because it must be retained for statutory
archiving purposes (e.g. for tax purposes, generally ten years). Data disclosed to us as part of an order
by the contractual partner will be deleted in accordance with the specifications and generally after
completion of the order.

Types of data processed: Inventory data (e.g. full name, residential address, contact
information, customer number, etc.); payment data (e.g. bank details, invoices, payment history); contact
data (e.g. postal and e-mail addresses or telephone numbers); contract data (e.g. subject matter of the
contract, term, customer category); usage data (e.g. page views and length of stay, click paths, usage
intensity and frequency, device types and operating systems used, interactions with content and functions);
meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, persons involved).

Data subjects: Service recipients and clients; interested parties; business and contractual
partners.

Purposes of processing: Performance of contractual services and fulfilment of contractual
obligations; security measures; communication; office and organisational procedures; organisational and
administrative procedures; business processes and business management procedures.

Retention and deletion: Deletion in accordance with the information provided in the section
“General Information on Data Storage and Deletion”.

Legal bases: Performance of a contract and pre-contractual enquiries (Art. 6 (1) (b) GDPR);
legal obligation (Art. 6 (1) (c) GDPR); legitimate interests (Art. 6 (1) (f) GDPR).

Further information on processing operations, procedures and services:

Online shop, order forms, e-commerce and performance of services:
We process our customers’ data in order to enable them to select, purchase or order the chosen products,
goods and related services, as well as to pay for and receive or have them delivered or performed. Where
necessary for the execution of an order, we use service providers, in particular postal, forwarding and
shipping companies, to carry out delivery or performance for our customers. For the processing of payments,
we use the services of banks and payment service providers. The required information is marked as such during
the ordering or comparable purchasing process and includes the information necessary for delivery or provision
and billing, as well as contact information so that we can consult with the customer if necessary;
legal basis: performance of a contract and pre-contractual enquiries (Art. 6 (1) (b) GDPR).

Provision of the Online Offering and Web Hosting

We process users’ data in order to provide them with our online services. For this purpose, we process the
user’s IP address, which is necessary to transmit the content and functions of our online services to the
user’s browser or device.

Types of data processed: Usage data (e.g. page views and length of stay, click paths,
usage intensity and frequency, device types and operating systems used, interactions with content and
functions); meta, communication and process data (e.g. IP addresses, timestamps, identification numbers,
persons involved); log data (e.g. log files related to logins or the retrieval of data or access times);
content data (e.g. text or image messages and contributions and information relating to them, such as
details of authorship or time of creation).

Data subjects: Users (e.g. website visitors, users of online services).

Purposes of processing: Provision of our online offering and user-friendliness; information
technology infrastructure (operation and provision of IT systems and technical equipment (computers, servers,
etc.)); security measures; firewall.

Retention and deletion: Deletion in accordance with the information provided in the section
“General Information on Data Storage and Deletion”.

Legal bases: Legitimate interests (Art. 6 (1) (f) GDPR).

Further information on processing operations, procedures and services:

• Provision of the online offering on rented storage space:
  For the provision of our online offering, we use storage space, computing capacity and software which we
  rent or otherwise obtain from a corresponding server provider (also referred to as a “web host”);
  legal basis: legitimate interests (Art. 6 (1) (f) GDPR).

• Collection of access data and log files:
  Access to our online offering is logged in the form of so-called “server log files”. The server log files
  may include the address and name of the retrieved web pages and files, date and time of retrieval, volume
  of data transferred, report of successful retrieval, browser type and version, the user’s operating system,
  referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider.
  The server log files may be used, on the one hand, for security purposes, e.g. to avoid overloading the
  servers (in particular in the case of abusive attacks such as DDoS attacks), and on the other hand, to
  ensure the utilisation and stability of the servers;
  legal basis: legitimate interests (Art. 6 (1) (f) GDPR).
  Deletion of data: Log file information is stored for a maximum period of 30 days and
  subsequently deleted or anonymised. Data whose further retention is required for evidence purposes are
  excluded from deletion until the respective incident has been finally clarified.

• ALL-INKL: Services in the field of providing information technology infrastructure and
  related services (e.g. storage space and/or computing capacities);
  service provider: ALL-INKL.COM – Neue Medien Münnich, owner: René Münnich, Hauptstraße 68,
  02742 Friedersdorf, Germany;
  legal basis: legitimate interests (Art. 6 (1) (f) GDPR);
  website:
  
  https://all-inkl.com/
  ;
  privacy policy:
  
  https://all-inkl.com/datenschutzinformationen/
  .
  A data processing agreement is provided by the service provider.

• Wordfence: Firewall and security as well as error detection functions to identify and
  prevent unauthorised access attempts and technical vulnerabilities that could enable such access. For these
  purposes, cookies and similar storage technologies necessary for this purpose may be used, and security
  logs may be created during monitoring and in particular in the event of unauthorised access. In this context,
  users’ IP addresses, a user identification number and their activities including the time of access are
  processed and stored and compared with data provided by the provider of the firewall and security function
  and transmitted to that provider;
  service provider: Defiant, Inc., 800 5th Ave Ste 4100, Seattle, WA 98104, USA;
  legal basis: legitimate interests (Art. 6 (1) (f) GDPR);
  website:
  
  https://www.wordfence.com
  ;
  privacy policy:
  
  https://www.wordfence.com/privacy-policy/
  ;
  basis for third-country transfer:
  Standard Contractual Clauses (
  
  https://www.wordfence.com/standard-contractual-clauses/
  ).
  Further information:
  
  https://www.wordfence.com/help/general-data-protection-regulation/
  .

Use of Cookies

The term “cookies” is used to describe functions that store information on users’ devices and read such
information from them. Cookies may also be used for various purposes, e.g. to ensure the functionality,
security and convenience of online offerings as well as to analyse user flows. We use cookies in accordance
with the legal requirements. Where necessary, we obtain users’ consent in advance. Where consent is not
required, we rely on our legitimate interests. This is the case where storing and reading information is
essential in order to provide explicitly requested content and functions. This includes, for example, the
storage of settings and ensuring the functionality and security of our online offering. Consent can be
withdrawn at any time. We provide clear information about the scope of use and which cookies are used.

Notes on the legal bases for data protection:
Whether we process personal data by means of cookies depends on whether consent is given. Where consent is
obtained, it serves as the legal basis. Where consent is not required, we rely on our legitimate interests,
as explained above in this section and in the context of the respective services and procedures.

Retention period:
With regard to the retention period, the following types of cookies are distinguished:

• Temporary cookies (session cookies):
  Temporary cookies are deleted at the latest after a user has left an online offering and closed their
  device (e.g. browser or mobile app).

• Permanent cookies:
  Permanent cookies remain stored even after the device has been closed. For example, the login status can be
  saved and preferred content displayed directly when the user visits a website again. Likewise, user data
  collected via cookies may be used for reach measurement. Unless we provide explicit information on the type
  and retention period of cookies (e.g. when obtaining consent), users should assume that these are permanent
  cookies and that the retention period can be up to two years.

General information on withdrawal and objection (opt-out):
Users can withdraw consent they have given at any time and may also object to processing according to the legal
requirements, including by means of the privacy settings of their browser.

Cookie settings / option to object: