Privacy policy

Data Protection Declaration

1) Information on the Collection of Personal Data and Contact Details of the Controller

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 controller in charge for data processing on this website within the meaning of the General Data Protection Regulation (GDPR) is Triumph Global Sales AG, Triumphweg 6, 5330 Bad Zurzach, Switzerland, E-Mail: service@uk.sloggi.com. The controller in charge of the processing of personal data is the natural or legal person who alone or jointly with others determines the purposes and means of the processing of personal data.

1.3 The controller has designated a data protection officer for this website. He can be reached as follows: “dpo@triumph.com”

1.4 This website uses SSL or TLS encryption for security reasons and to protect the transmission of personal data and other confidential content (e.g. orders or inquiries to the controller). You can recognize an encrypted connection by the character string https:// and the lock symbol in your browser line.

2) Data Collection When You Visit Our Website

When using our website for information only, 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 moment 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 applicable: in anonymized form)

Data processing is carried out in accordance with Art. 6 (1) point 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 check the server log files subsequently, if there are any concrete indications of illegal use.

3) Cookies

In order to make your visit to our website attractive and to enable the use of certain functions, we use so-called cookies on various pages. These are small text files that are stored on your end device. Some of the cookies we use are deleted after the end of the browser session, i.e. after closing your browser (so-called session cookies). Other cookies remain on your terminal and enable us or our partner companies (third-party cookies) to recognize your browser on your next visit (persistent cookies). If cookies are set, they collect and process specific user information such as browser and location data as well as IP address values according to individual requirements. Persistent cookies are automatically deleted after a specified period, which may vary depending on the cookie.

In some cases, cookies are used to simplify the ordering process by saving settings (e.g. remembering the content of a virtual shopping basket for a later visit to the website). If personal data are also processed by individual cookies set by us, the processing is carried out in accordance with Art. 6 (1) point b GDPR either for the execution of the contract or in accordance with Art. 6 (1) point f GDPR to safeguard our legitimate interests in the best possible functionality of the website and a customer-friendly and effective design of the page visit.
We work together with advertising partners who help us to make our website more interesting for you. For this purpose, cookies from partner companies are also stored on your hard drive when you visit our website (third-party cookies). You will be informed individually and separately about the use of such cookies and the scope of the information collected in each case within the following sections.

Please note that you can set your browser in such a way that you are informed about the setting of cookies and you can decide individually about their acceptance or exclude the acceptance of cookies for certain cases or generally. 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
Google: 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: http://help.opera.com/Windows/10.20/en/cookies.html

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

4) Contacting

In the context of contacting us (e.g. via contact form or e-mail), personal data is collected. Which data is collected in the case of a contact form can be seen from the respective contact form. These data are stored and used exclusively for the purpose of responding to your request or for establishing contact and for the associated technical administration. The legal basis for processing data is our legitimate interest in responding to your request in accordance with Art. 6 (1) point f GDPR. If your contact is aimed at concluding a contract, the additional legal basis for the processing is Art. 6 (1) point b GDPR. Your data will be deleted after final processing of your enquiry; this is the case if it can be inferred from the circumstances that the facts in question have been finally clarified, provided that there are no legal storage obligations to the contrary.

5) Data Processing When Opening a Customer Account and for Contract Processing

Pursuant to Art. 6 (1) point b GDPR, personal data will continue to be collected and processed if you provide them to us for the execution of a contract or when opening a customer account. Which data is collected can be seen from the respective input forms. It is possible to delete your customer account at any time. This can be done by sending a message to the above-mentioned address of the controller. We store and use the data provided by you for contract processing. After complete processing of the contract or deletion of your customer account, your data will be blocked in consideration of tax and commercial retention periods and deleted after expiry of these periods, unless you have expressly consented to further use of your data or a legally permitted further use of data has been reserved by our site, about which we will inform you accordingly below.

6) Use of Your Data for Direct Advertising

6.1 If you subscribe to our e-mail newsletter, we will send you regular information about our offers. The only mandatory information for sending the newsletter is your e-mail address. The indication of additional possible data is voluntary and is used to be able to address you personally. We use the so-called double opt-in procedure for sending the newsletter. This means that we will not send you an e-mail newsletter, unless you have expressly confirmed to us that you agree to the sending of the newsletter. We will then send you a confirmation e-mail asking you to confirm that you wish to receive future newsletters by clicking on an appropriate link.

By activating the confirmation link, you give us your consent to the use of your personal data in accordance with Art. 6 (1) point a GDPR. When you register for the newsletter, we store your IP address entered by the Internet Service Provider (ISP) as well as the date and time of registration so that we can trace any possible misuse of your e-mail address at a later time. The data collected by us when registering for the newsletter will be used exclusively for the purpose of advertising by means of the newsletter. You can unsubscribe from the newsletter at any time via the link provided in the newsletter or by sending a message to the responsible person named above. After your cancellation, your e-mail address will immediately be deleted from our newsletter distribution list, unless you have expressly consented to further use of your data or we reserve the right to use data in excess thereof, which is permitted by law and about which we inform you in this declaration.

6.2 Based on our legitimate interest in personalized direct mail, we reserve the right to store your first and last name, your postal address and – if we have received this additional information from you within the framework of the contractual relationship – your title, academic degree, year of birth and your professional, industry or business name in accordance with Art. 6 (1) point f GDPR and to use them for sending interesting offers and information on our products by letter post.

You can object to the storage and use of your data for this purpose at any time by sending an appropriate message to the controller.

7) Processing of Data for the Purpose of Order Handling

7.1 To process your order, we work together with the following service provider(s), which support us wholly or partially in the execution of concluded contracts. Certain personal data is transferred to these service providers in accordance with the following information.

The personal data collected by us will be passed on to the transport company commissioned with the delivery within the scope of contract processing, insofar as this is necessary for the delivery of the goods. We will pass on your payment data to the commissioned credit institution within the framework of payment processing, if this is necessary for payment handling. If payment service providers are used, we explicitly inform you of this below. The legal basis for the transfer of data is Art. 6 (1) point b GDPR.

7.2 Use of Payment Service Providers

– Paypal
When paying via PayPal, credit card via PayPal, direct debit via PayPal or – if offered – “purchase on account” or “payment by instalments” via PayPal, we transmit your payment data to PayPal (Europe) S.a.r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg (hereinafter “PayPal”). The transfer takes place in accordance with Art. 6 (1) point b GDPR and only insofar as this is necessary for payment processing.
PayPal reserves the right to carry out credit checks for the payment methods credit card via PayPal, direct debit via PayPal or, if offered, “purchase on account” or “payment by installments” via PayPal. For this purpose, your payment data may be passed on to credit agencies on the basis of PayPal’s legitimate interest in determining your solvency pursuant to Art. 6 (1) point f GDPR. PayPal uses the result of the credit assessment in relation to the statistical probability of non-payment for the purpose of deciding on the provision of the respective payment method. The credit report can contain probability values (so-called score values). If score values are included in the result of the credit report, they are based on recognized scientific, mathematical-statistical methods. The calculation of the score values includes, but is not limited to, address data. For further information on data protection law, including the credit agencies used, please refer to PayPal’s data protection declaration at: https://www.paypal.com/uk/webapps/mpp/ua/privacy-full.
You can object to this processing of your data at any time by sending a message to PayPal. However, PayPal may still be entitled to process your personal data if this is necessary for contractual payment processing.
– Wirecard
If you choose one of the payment methods offered by the payment service provider checkoutportal by wirecard, payment is processed via the payment service provider checkoutportal by wirecard, Wirecard UK & Ireland Ltd, 1st Floor Ulysses House,Foley Street Dublin 1, Ireland, to whom we pass on your information provided during the order process together with the information about your order (name, address, if applicable IBAN, possibly BIC, invoice amount, currency and possibly transaction number). Your data will only be passed on to the payment service provider checkoutportal by wirecard for the purpose of payment processing in accordance with Art. 6 (1) point b GDPR. Your data will only be passed on if this is necessary for processing the payment.

8) Contact for Requesting Customer Rating Information

Evaluation Reminder by Trusted Shops
If you have given us your express consent during or after your order in accordance with Art. 6 (1) point a GDPR, we will send your e-mail address to the evaluation platform Trusted Shops GmbH, Subbelrather Str. 15c, 50823 Köln (www.trustedshops.it), so that it can send you an evaluation reminder by e-mail. You can revoke your consent at any time by sending a message to the controller responsible for data processing or to the evaluation platform.

9) Use of Videos

Use of Youtube Videos

This website uses the Youtube embedding function for display and playback of videos offered by the provider Youtube, which belongs to Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”).

To this end, the extended data protection mode is used to ensure, according to provider information, that user information will only be stored once the playback function of the video is started. When the playback of embedded YouTube videos is started, the provider sets “YouTube” cookies in order to collect information about user behavior. According to indications from Youtube, the use of those cookies is intended, among other things, to record video statistics, to improve user-friendliness and to avoid improper actions. If you are logged in to Google, your information will be directly associated with your account when you click on a video. If you do not wish to be associated with your profile on YouTube, you must log out before activating the button. Google saves your data (even for users who are not logged in) as usage profiles and evaluates them. Such an evaluation takes place in particular according to Art. 6 (1) point f GDPR on the basis of the legitimate interests of Google in the insertion of personalized advertising, market research and/or demand-oriented design of its website. You have the right to object to the creation of these user profiles, whereby you must contact YouTube to exercise this right.

Regardless of whether the embedded video is played back, a connection to the Google network “double click” is established when visiting this website. This may trigger further data processing beyond our control.

Google LLC, based in the USA, is certified for the US-European data protection agreement “Privacy Shield”, which guarantees compliance with the data protection level applicable in the EU.

Further information on YouTube data protection can be found in the provider’s data protection statement at: www.google.com/policies/privacy/

10) Online-Marketing

Google AdWords Conversion Tracking

This website uses the online advertising program “Google AdWords” and the conversion tracking within the framework of Google AdWords, Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). We use the program of Google Adwords to draw attention to our attractive offers with the help of advertising materials (so-called Google Adwords) on external websites. We can determine, in relation to the advertising campaigns data, how successful the individual advertising measures is. We are interested in showing you advertisements that are of interest to you. We want to make our website more interesting for you and to achieve a fair calculation of advertising costs.

The conversion tracking cookie is set on a user’s browser, if he clicks on an AdWords ad delivered by Google. Cookies are small text files that are stored on your computer system. These cookies usually lose their validity after 30 days and are not used for personal identification. If the user visits a certain page of this website and if the cookie has not yet expired, Google and we will be able to recognize that the user clicked on the ad and was forwarded to this page. Each Google AdWords customer gets a different cookie. Thus, cookies cannot be traced via the website of AdWords customers. The information collected by the conversion cookies is used to provide aggregate conversion statistics to AdWords customers who have opted-in for conversion tracking. Customers are informed about the total number of users who clicked on the ad and were forwarded to a conversion tracking tag page. However, they do not get any information enabling them to identify users personally. If you do not want to participate in the tracking program, you can refuse the use of this program by deactivating the Google Conversion Tracking cookie via your Internet browser through the user settings. In this case, you will not be included in the conversion tracking statistics. We use Google Adwords on the basis of our legitimate interest in targeted advertising in accordance with Art. 6 (1) point f GDPR.

Google LLC, based in the United States, is certified for the US-European data protection agreement “Privacy Shield”, which guarantees compliance with the data protection level applicable in the EU.

For more information about Google’s privacy policy, please visit: https://privacy.google.com/intl/en-GB/take-control.html?categories_activeEl=sign-in

You can permanently deactivate cookies for advertising preferences by blocking them via a respective setting of your browser software or by downloading and installing the browser plug-in, available under the following link:
https://support.google.com/ads/answer/7395996

Please note that certain functions of this website may not be used or only to a limited extent, if you have deactivated the use of cookies.

11) Web Analysis Services

Google (Universal) Analytics

– Google Universal Analytics
This website uses Google Analytics, a web analysis service of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). Google Analytics uses so-called cookies, which are text files stored on your computer, to help the website analyze how users use the site. The information generated by the cookies about your use of this website (including the shortened IP address) is generally transmitted to a Google server in the USA and stored there.
This website uses Google Analytics exclusively with the extension “_anonymizeIp()”, which ensures an anonymization of the IP address by shortening it and excludes a direct personal relationship. As a result of the extension, your IP address will previously be shortened by Google within member states of the European Union or in other signatory states to the Agreement on the European Economic Area. Only in exceptional cases, the full IP address will be transmitted to a Google server in the USA and shortened there. In these exceptional cases, processing is carried out in accordance with Art. 6 (1) point f GDPR on the basis of our legitimate interest in the statistical analysis of user behavior for optimization and marketing purposes.
On our behalf, Google will use this information to evaluate your use of the website, to compile reports on website activity and to provide us with other services relating to website and internet use. The IP address transmitted by your browser in the context of Google Analytics is not merged with other Google data.
You may refuse the use of cookies by selecting the appropriate settings on your browser. However, we should point out that in that case you might not be able to use the full functionality of this website. You may permanently refuse Google to collect data generated by cookies regarding the use of the website (including your IP address) and to process them. You can download and install the browser plugin available under the following link: https://tools.google.com/dlpage/gaoptout?hl=en.
As an alternative to the browser plug-in or for browsers on mobile devices, please click on the following link in order to set an opt-out cookie which disables Google Analytics to collect data on this website in the future (this opt-out cookie only functions for this browser and this domain. If you delete your cookies on this browser, you must click again on this link):
Disable Google Analytics
Google LLC, based in the United States, is certified for the US-European data protection agreement “Privacy Shield”, which guarantees compliance with the data protection level applicable in the EU.
This website also uses Google Analytics for a device-independent analysis of visitor flows, which is carried out via a user ID. You can deactivate the cross-device analysis of your usage in your customer account under “My data”, “Personal data”.
More information on how Google Analytics handles user data can be found in Google’s privacy policy at: https://support.google.com/analytics/answer/6004245?hl=en

12) Retargeting/Remarketing/ Referral Advertising

Bing Ads (Microsoft Corporation)
This website uses the conversion tracking technology “Bing Ads” from Microsoft (Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA). Microsoft Bing Ads will place a cookie on your computer if you access our website via a Microsoft Bing ad. Cookies are small text files that are stored on your computer system. These cookies lose their validity after 180 days. They are not meant for personal identification. If the user visits certain pages of this website and if the cookie has not yet expired, we and Microsoft are able to recognize that the user has clicked the ad and has been forwarded to this page (conversion page). If personal data are processed in this context, this is done in accordance with Art. 6 (1) point f GDPR on the basis of our legitimate interest in effective marketing.
The information collected via the conversion cookie is meant to compile conversion statistics, i.e. to register how many users have arrived at a conversion page after clicking the ad. We hereby learn the total number of users who clicked our ad and were forwarded to a conversion tracking tag page. However, we do not obtain any information by which users can be personally identified.
Microsoft Corporation, based in the United States, is certified for the US-European data protection agreement “Privacy Shield”, which guarantees compliance with the data protection level applicable in the EU.
If you do not wish to participate in tracking, you may object to this usage by easily deactivating the Bing Ads conversion tracking cookie via your internet browser and your user settings. In this case, you will not be included in the conversion tracking statistics. Alternatively, you can use the deactivation page for consumers from the EU http://www.youronlinechoices.com/uk/your-ad-choices/
to check whether Microsoft advertising cookies are set in your browser and, if so, to deactivate them.
For more information about Microsoft Bing Ads’ privacy policy, please visit: https:// https://privacy.microsoft.com/en-US/

Criteo (Criteo SA)
This website uses the technology of Criteo SA, 32 Rue Blanche, 75009 Paris, France (“Criteo”), to collect, store and evaluate information about the surfing behavior of website visitors in pseudonymized form using cookie text files. This is done on the basis of our legitimate interest in the insertion of personalized advertising pursuant to Art. 6 (1) (f) GDPR. Criteo analyses the navigation behavior with the help of algorithms and is subsequently able to display product recommendations in form of personalized advertising banners on other websites (so-called publishers). Under no circumstances, those data will be used to personally identify the visitor to this website. No other use or disclosure to third parties is envisaged.
If you want to object to the collection of data and the creation of pseudonymized user profiles for the future, you can obtain the following so-called opt-out cookie: Criteo Exercise (https://www.criteo.com/fr/privacy/)
For more information about Criteo’s technology, please view Criteo’s Privacy Policy at: https://www.criteo.com/privacy/

Facebook Custom Audience via the Pixel Process
This website uses the “Facebook Pixel” of Facebook Inc, 1 Hacker Way, Menlo Park, CA 94025, USA (“Facebook”). If the user has given us his explicit consent, his behavior can be tracked after he has seen or clicked on a Facebook advertisement. This process is designed to evaluate the impact of Facebook ads for statistical and market research purposes and may help to optimize future advertising efforts.
Data collected shall remain anonymous and cannot be used to draw any conclusion about the identity of the user. However, those data are stored and processed by Facebook to enable a connection to the respective user profile and to allow Facebook to use those data for its own advertising purposes in accordance with the Facebook Privacy Policy (https://www.facebook.com/about/privacy/). You may allow Facebook and its partners to place ads on and outside of Facebook. A cookie may also be stored on your computer for these purposes. These processing operations only take place if express consent is given in accordance with Art. 6 (1) point a GDPR.
Consent to the use of the Facebook pixel may only be given by users who are older than 13 years of age. If you are younger, please ask your legal guardian for permission.
Facebook Inc., based in the United States, is certified for the US-European data protection agreement “Privacy Shield”, which guarantees compliance with the data protection level applicable in the EU.
If you want to disable the use of cookies on your computer, you can set your Internet browser so that cookies can no longer be stored on your computer in the future and/or cookies that have already been stored will be deleted. However, when disabling all cookies, some functions of our internet pages may no longer be able to be executed. You can also disable the use of cookies by third parties such as Facebook on the following Digital Advertising Alliance website: http://www.aboutads.info/choices/

Google AdWords Remarketing
Our website uses the functions of Google AdWords Remarketing, which enable us to advertise our website in Google search results, as well as on third-party websites. Provider is Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). To this end, Google places a cookie in the browser of your terminal device, which automatically uses a pseudonymous cookie ID on the basis of pages you visited to allow interest-based advertising. Processing is based on our legitimate interest in the optimal marketing of our website in accordance with Art. 6 (1) point f GDPR.
Any additional processing will only take place if you have agreed with Google that your Google Internet and app browsing history will be linked to your Google Account and information from your Google Account will be used for personalized ads you view on the web. If you are logged in to Google while visiting our website, Google will use your data in connection with Google Analytics data to create and define target group lists for cross-device remarketing. To this end, Google temporarily links your personal data with Google Analytics data to create target groups.
You can permanently disable the setting of cookies for advertising preferences. You may download and install the browser plug-in available at the following link: https://www.google.com/settings/ads/onweb/
Alternatively, you can contact the Digital Advertising Alliance at www.aboutads.info to find out how to set cookies and to make the relevant settings. Finally, you can set your browser so that you are informed about the setting of cookies and decide individually whether to accept them or to exclude the acceptance of cookies for certain cases or in general. If cookies are not accepted, the functionality of our website may be limited.
Google LLC, based in the United States, is certified for the US-European data protection agreement “Privacy Shield”, which guarantees compliance with the data protection level applicable in the EU.
Further information and the data protection regulations regarding advertising and Google can be viewed at:
http://www.google.com/policies/technologies/ads/

13) Tools and Miscellaneous

13.1 Google Maps

Our website uses Google Maps (AP’I) of Google LLC., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). Google Maps is a web service for displaying interactive (country) maps in order to display geographical information visually. Using this service will show you our location and will make it easier for you to find us.

When you access the sub-pages that contain the Google Maps map, information about your use of our website (such as your IP address) is transmitted to and stored by Google on servers in the United States. This is regardless of whether Google provides a user account that you are logged in with or whether no user account exists. If you are logged in to Google, your information will be directly associated with your account. If you do not wish to be associated with your profile on Google, you must log out before activating the button. Google saves your data (even for users who are not logged in) as usage profiles and evaluates them. Such an evaluation takes place according to Art. 6 (1) point f GDPR on the basis of the legitimate interests of Google in the insertion of personalized advertising, market research and/or demand-oriented design of its website. You have the right to object to the creation of these user profiles. If you want to do so, you must contact Google to exercise this right.

Google LLC, based in the United States, is certified for the US-European data protection agreement “Privacy Shield”, which guarantees compliance with the data protection level applicable in the EU.

If you do not agree to the future transmission of your data to Google in the context of using Google Maps, you may completely deactivate the Google Maps web service by switching off the JavaScript application in your browser. In this case, Google Maps as well as the map display on this website cannot be used.
The Google terms of use can be found at: https://policies.google.com/terms?hl=en. The additional terms of use can be found at: https://www.google.com/intl/en-US_US/help/terms_maps.html.

You can find detailed information on data protection in connection with the use of Google Maps on Google’s website (“Google Privacy Policy”) at: https://policies.google.com/privacy?hl=en.

13.2 The Trusted Shops Trustbadge is included on this website to display our Trusted Shops seal of approval and to offer Trusted Shops membership to buyers after placing an order.

In this way, our legitimate interests in an optimal marketing of our offer are protected, within the meaning of Art. 6 (1) point f GDPR. The Trustbadge and the services advertised with it are a service of Trusted Shops GmbH, Subbelrather Str. 15C, 50823 Cologne.

When the trust badge is called up, the web server automatically stores a so-called server log file, which contains e.g. your IP address, date and time of the call, transferred data volume, the requesting provider (access data) and it documents the call. This access data is not evaluated and is automatically overwritten at the latest seven days after the end of your page visit.

Further personal data will only be transferred to Trusted Shops if you decide to use Trusted Shops products after completing an order or if you have already registered for use. In this case, the contractual agreement between you and Trusted Shops applies.

14) Rights of the Data Subject

14.1 The applicable data protection law grants you comprehensive rights of data subjects (rights of information and intervention) vis-à-vis the data controller with regard to the processing of your personal data, about which we inform you below :

  • Right of access by the data subject pursuant to Art. 15 GDPR
  • Right to rectification pursuant to Art. 16 GDPR
  • Right to erase (“right to be forgotten”) pursuant to Art. 17 GDPR
  • Right to restriction of processing pursuant to Art. 18 GDPR
  • Right to be informed pursuant to Art. 19 GDPR
  • Right to data portability pursuant to Art. 20 GDPR
  • Right to withdraw a given consent pursuant to Art. 7 (3) GDPR
  • Right to lodge a complaint pursuant to Art. 77 GDPR

14.2 RIGHT TO OBJECT

IF, WITHIN THE FRAMEWORK OF A CONSIDERATION OF INTERESTS, WE PROCESS YOUR PERSONAL DATA ON THE BASIS OF OUR PREDOMINANT LEGITIMATE INTEREST, YOU HAVE THE RIGHT AT ANY TIME TO OBJECT TO THIS PROCESSING WITH EFFECT FOR THE FUTURE ON THE GROUNDS THAT ARISE FROM YOUR PARTICULAR SITUATION.
IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL STOP PROCESSING THE DATA CONCERNED. HOWEVER, WE RESERVE THE RIGHT TO FURTHER PROCESSING IF WE CAN PROVE COMPELLING REASONS WORTHY OF PROTECTION FOR PROCESSING WHICH OUTWEIGH YOUR INTERESTS, FUNDAMENTAL RIGHTS AND FREEDOMS, OR IF THE PROCESSING SERVES TO ASSERT, EXERCISE OR DEFEND LEGAL CLAIMS.

IF WE PROCESS YOUR PERSONAL DATA FOR DIRECT MARKETING PURPOSES, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF YOUR PERSONAL DATA WHICH ARE USED FOR DIRECT MARKETING PURPOSES. YOU MAY EXERCISE THE OBJECTION AS DESCRIBED ABOVE.

IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL STOP PROCESSING THE DATA CONCERNED FOR DIRECT ADVERTISING PURPOSES.

15) Duration of Storage of Personal Data

The duration of the storage of personal data is determined by the respective legal retention period (e.g. commercial and tax retention periods). After expiry of this period, the corresponding data will be routinely deleted, provided they are no longer necessary for the performance or initiation of the contract and/or there is no longer any legitimate interest on our part in the further storage.

Cookies

3) Cookies

In order to make your visit to our website attractive and to enable the use of certain functions, we use so-called cookies on various pages. These are small text files that are stored on your end device. Some of the cookies we use are deleted after the end of the browser session, i.e. after closing your browser (so-called session cookies). Other cookies remain on your terminal and enable us or our partner companies (third-party cookies) to recognize your browser on your next visit (persistent cookies). If cookies are set, they collect and process specific user information such as browser and location data as well as IP address values according to individual requirements. Persistent cookies are automatically deleted after a specified period, which may vary depending on the cookie.

In some cases, cookies are used to simplify the ordering process by saving settings (e.g. remembering the content of a virtual shopping basket for a later visit to the website). If personal data are also processed by individual cookies set by us, the processing is carried out in accordance with Art. 6 (1) point b GDPR either for the execution of the contract or in accordance with Art. 6 (1) point f GDPR to safeguard our legitimate interests in the best possible functionality of the website and a customer-friendly and effective design of the page visit.
We work together with advertising partners who help us to make our website more interesting for you. For this purpose, cookies from partner companies are also stored on your hard drive when you visit our website (third-party cookies). You will be informed individually and separately about the use of such cookies and the scope of the information collected in each case within the following sections.

Please note that you can set your browser in such a way that you are informed about the setting of cookies and you can decide individually about their acceptance or exclude the acceptance of cookies for certain cases or generally. 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
Google: 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: http://help.opera.com/Windows/10.20/en/cookies.html

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

Facebook Privacy Policy

PRIVACY POLICY FOR FACEBOOK FANPAGE

1) CONTROLLER

As the operator of this Facebook page, we (Triumph International, Arkwright Rd, Swindon, SN25 5BE) together with the operator of the social network Facebook (Facebook Ireland Ltd.) are controller within the meaning of Art. 4 No.7 of the General Data Protection Regulation (GDPR). When visiting our Facebook page, personal data is processed by those responsible. In the following, we will inform you about the affected data, the way in which the data is processed and the rights you are entitled to.

As the person in charge of this site, we have made agreements with Facebook, which, among other things, regulate the conditions for using the Facebook page. Decisive are the Terms of Service of Facebook as well as the other conditions and guidelines listed at the end.

2) USE OF INSIGHTS AND COOKIES

In connection with the operation of this Facebook page, we use the Insights feature of Facebook to obtain anonymous statistical data about the users of our Facebook page. For this purpose, Facebook stores a cookie on the user’s device that visits our Facebook page. The cookie contains a unique user code and is active for a period of two years, unless it is deleted beforehand. The user code can be linked to the data of users who are registered with Facebook.

The information stored in the cookies is received, recorded and processed by Facebook, in particular, when the user visits the Facebook services, services provided by other members of the Facebook-group, and services provided by other companies using the Facebook services. In addition, other sites, such as Facebook-Partners or even third parties on the Facebook services, may use cookies to provide services to Facebook advertising companies. Further information on the use of cookies by Facebook can be found in their cookie policy.

3) PURPOSE OF PROCESSING

The processing of the information enables Facebook to improve its advertising system, which is distributed via its network, and allows us as the operator of the Facebook page to obtain statistics that Facebook creates based on the visits to our Facebook page. This is intended to control the marketing of our activity. For example, it enables us to gain knowledge of the profiles of visitors who value our Facebook page or use the site’s applications to provide them with more relevant content and to develop features that may be of greater interest to them.

To better understand how we can achieve our goals with our Facebook page, demographic and geographical evaluations are created and made available to us based on the information collected. We can use this information to specifically target interest-based ads without immediately knowing the identity of the visitor. If visitors use Facebook on multiple devices, the collection and evaluation can be done across devices, if they are registered users and are logged in their own profiles.

The generated visitor statistics are transmitted to us only in anonymous form. We have no access to the underlying data.

4) LEGAL BASIS AND AUTHORIZED INTERESTS

We operate this Facebook page to present our services and communicate with users of Facebook and other interested persons who are visiting our Facebook page. The processing of the personal data of users takes place on the basis of our legitimate interests for an optimized corporate presentation (Article 6 (1) (f) GDPR).

5) DISTRIBUTION OF DATA

In some cases, it may be possible that some of the information collected may also be processed outside the European Union by the US-based Facebook Inc. Facebook Inc. is certified under the US-EU Data Protection Agreement »Privacy Shield« and is therefore committed to comply with European data protection regulations.

We ourselves do not share personal data.

6) OPTIONS TO OBJECT

Users of Facebook can decide under the settings for advertising preferences to what extent their user behaviour may be recorded when visiting our Facebook page. Other options are the Facebook settings or the form for the right to object.

The processing of information by means of the cookies used by Facebook can be prevented by disabling cookies from third-parties or Facebook in the browser settings.

7) COMMON RESPONSIBILITY

As the owner and operator of the Facebook social network, Facebook as the joint controller of our Facebook page is ultimately responsible for the handling and processing of data subject requests and the exercising of further data protection rights. As provider of the social network and due to the ability to integrate Facebook pages, Facebook alone has the immediate access to required information and can immediately take any necessary action and provide information. However, should our support be required, we can be contacted at any time.

8) CONTACT AND OTHER RIGHTS OF THE DATA SUBJECT

Further information in regards to the rights of data subjects, the way personal data is processed by us and our contact details can be found in the privacy policy on our website.

Information on handling personal data by Facebook can be found in their privacy policy.

Imprint

This website is made available to you by

Member of the Managing Board – Karl-Heinz Gerl

Inter-Triumph Marketing GmbH
Marsstrasse 40
80335 Munich

Contact
Tel: + 49 (0) 89 511180
Local Court Munich: HRB 5682.
VAT-ID: DE 811170293

Modern Slavery Act Transparency Statement

2017

 

This statement is made pursuant to Section 54 of the Modern Slavery Act 2015. It constitutes Triumph International‘s slavery and human trafficking statement for the financial year 2017

 

Introduction

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking.

We understand that modern slavery is a global issue that may affect our organisation and our supply chains alike.

 

Triumph possesses subsidiaries around the world, covering significant parts of its value chain from design to selling. Throughout our history, we were able to demonstrate our sense for fashion, excellent insights into the individual desires and changing needs of our consumers as well as a caring and engaging approach to our employees and society.

For over a century, Triumph continuously strived to recruit new talent, offering them one of the textile industry’s most international working environments, excellent conditions and great development opportunities in an ever-evolving company.

We manufacture in socially compliant and high tech production facilities, a number  of them owned and operated directly by us, using environmentally friendly and energy-saving production methods and the most modern and skin-friendly material.

Since 2012, our organisation has been an active participant of the Business Social Compliance Initiative (BSCI), which supports companies to drive social compliance and improvements within the factories in their global supply chains.

We endorse the Triumph Code of Conduct and, as a BSCI Partner, we endorse the BSCI Code of Conduct and its terms of implementation and cascade them through our supply chains. Accordingly, the Triumph Group does not tolerate any form of slavery, servitude, forced, compulsory labour and human trafficking and commits strongly to the early detection, monitoring and remediation of such issues in its supply chains. We remain open to constructive engagement with stakeholders who can help to combat this phenomenon.

 

For more, detailed information please visit: http://www.triumph.com/uk/en/7753.html

Organizational structure

 International

The Triumph Group, one of the world´s leading intimate apparel companies, has been founded in Germany in 1886. Today, it is headquartered in Bad Zurzach (Switzerland) and continues to be a fully privately owned company.

Triumph today enjoys a presence in over 120 countries all across the world. For its brands Triumph and sloggi the company develops, produces and sells underwear, lingerie, sleepwear and swimwear.

Triumph supplies 40,000 wholesale customers worldwide and sells its products in 3,600 controlled points of sale as well as via several own online shops. Currently Triumph employs close to 25,000 people worldwide.

 

UK

Triumph supplies more than 400 wholesale customers and sells its products in two Triumph stores and one Factory Outlet as well as numerous online shops. Currently Triumph employs over 100 people in UK.

 

Supply chain structure

Many of our products are manufactured in five Triumph own manufacturing facilities. Trusted and reliable partners in Europe, Africa and Asia, with whom we have typically collaborated for several years, are producing the rest. Our third party finished goods are continuously evaluated on various criteria including compliance. We expect our suppliers to comply with legal requirements as well as environmental and social standards and our Code of Conduct.

 

Internal Policies, procedures and contractual controls

Triumph is committed to conducting our business in a legal, responsible and sustainable manner that is ethically sound and concerned about the welfare of our people, communities, our stakeholders and the natural environment. Our Policy Framework sets the context within which we wish to sustain our successful business. It contains the principles and rules of corporate conduct to guide behaviour both within and outside of our company.

As a BSCI Partner, Triumph has developed the necessary management systems, policies and procedures to effectively prevent and address any adverse human rights impact that may be detected in its supply chains.

Social Compliance Policy:

Our Social Compliance Policy was originally rolled out in April 2012 in order to increase visibility, transparency and risk manageability for Finished Good Suppliers by providing a single and structured approach to identify, evaluate and, if necessary, disqualify suppliers.

Since then, we have implemented governance and compliance standards to uphold our commitment accordingly.

Simultaneously, Triumph joined BSCI in 2012 in order to drive sustainable improvements of labour and workplace conditions by adhering to both our own Code of Conduct as well as BSCI’s Code of Conduct, which include prevention of servitude, forced, bonded, indentured, trafficked or non-voluntary labour.

Business Ethics Guidelines:

Our values, principles and codes of conduct ensure that expectations around ethical behaviours are clear, monitored and that specific corrective actions are implemented in case of any violations.

 

For more, detailed information please visit: http://www.triumph.com/uk/en/7753.html

 

Due diligence and remediation in our own business and supply chains

As a BSCI Partner, Triumph commits to acting diligently in (a) assessing actual and potential adverse impacts of our business against the values and principles of the BSCI Code of Conduct; (b) identifying throughout the supply chain where the most significant risks for these adverse impacts may occur and (c) acting upon them with the aim of preventing and/or addressing them in line with the BSCI Code of Conduct.

In this context, we have undertaken the following due diligence steps:

 

Mapping and monitoring our supply chains

  • We have gathered and assessed reliable information about our business partners’ responsible behaviour, among others by using BSCI audits. In 2017, there were 115 audits being arranged on our business partners, out of those 96 were BSCI audits (see the graph below) and 19 in cooperation with other audit schemes such as WRAP, Better Works and SMETA etc.

Some factories were not audited in 2017 due to the following reasons:

  • Factories are located in low risk countries like Japan
  • Factories’ audits were still valid in 2017.
  • We have continuously requested that all our significant business partners sign the BSCI Code of Conduct and Terms of Implementation and asked them to pass it on to their own significant partners, creating a positive cascade effect.
  • We have also evaluated the risk of new suppliers by visiting all new factories in different teams, having human rights, health and safety taken into account before starting production there.

 

Grievance mechanism and worker’s involvement

 

  • Our organisation has put effective grievance and whistle blowing mechanisms in place as per BSCI Code of Conduct for individuals and communities who may be adversely impacted by our organization’s activity, including potential or factual forced labour.

 

  • We have set up an integrity hotline (integrity@triumph.com), which is an independent and confidential channel for receiving information relating to improper business conduct and open to both Triumph employees as well as third parties. Moreover, a solid partnership with our social partners as well as regular mutual feedback further reinforces this as well.

 

  • In addition, being a BSCI participant, any third party can lodge a grievance about our BSCI implementation activities through the amfori BSCI Grievance Mechanism [system@amfori.org].

 

Incidents of forced labour and remediation

 

Through BSCI audits, we have not identified any case of unacceptable performance under the heading of bonded labour. This means, among others that we have not been made aware that any of our business partners or own facilities has failed to:

  1. exercise due diligence to avoid engaging in any form of bonded labour – particularly when recruiting migrant workers directly or indirectly;
  2. implement prevention procedures and build knowledge to prevent forced labour and human trafficking through hiring;
  3. enforce vigilance to avoid inhumane or degrading treatment – including through disciplinary procedures.

In addition, through BSCI audits, we have not identified any case where the auditor alerted us of flagrant bonded labour or human trafficking that required imminent remediation from our side.

  

Stakeholder engagement and industry collaboration

 

  • Being a BSCI participant, we are part of an industry wide network that we use it to work collaboratively and exchange lessons learned and solutions in a pre-competitive basis

 

Assessment of Modern Slavery risk within our business and supply chain

To understand where we have the biggest risks, Triumph has undertaken the following risk assessment steps both in our own organization and in our supply chain:

With the help of the amfori BSCI tool, we have identified the severity of the risk in different sourcing countries. For countries with high risks (like China, Myanmar, Vietnam and Cambodia) our social compliance team would – apart from arranging the social compliance audit regularly (i.e. at least once a year generally) – with due diligence also arrange visits regularly for on-site evaluation. This is done to better understand the social compliance status of the factory which includes the evaluation on human resource policies, recruitment practice etc.

Country Risk Classification: http://duediligence.amfori.org/countryRiskClassification

 

Assessment of our effectiveness in preventing and combatting Modern Slavery

We are well aware that risks concerning forced labour, human trafficking and slavery are not static, therefore we regularly track, measure and evaluate our internal due diligence processes to better understand our performance, progress, effectiveness, remaining risks and impact of our own operations and those of our business partners.

The BSCI Commitment Formula helps Triumph to define overall goals and targets to assess our progress in achieving them. Combatting Modern Slavery, we recognize the following key targets to be monitored:

  • Our own staff increases awareness of forced labour and human rights risks, particularly those related to forced labour and human trafficking.

 

  • Our supply chains’ business partners show continuous improvement, particularly with regard to the BSCI Performance area on bonded labour.

 

Assessing the effectiveness of our measures on a regular basis helps Triumph to maintain efforts that have proven to be successful and allows the exploration of innovative solutions when needed.

 

Training and further steps

At Triumph, our employees are introduced to our Codes of Conduct, trained on our values and principles and asked to familiarize themselves with our corporate policies.

In addition, every finished goods factory is introduced to our Code of Conduct. Factories, which are audited on BSCI system, are further expected to cascade BSCI’s Code of Conduct down their supply chain to further drive awareness beyond the first tier. We also encourage our factories to partake in one of the many BSCI workshops to further reinforce BSCI’s Code of Conduct.

Going forward, we are planning to instil the concept of human rights and modern slavery more specifically into our own staff and to our business partners.

This statement has been approved by the Global Head of Supply Chain on 19th of July 2018 and constitutes Triumph International’s commitments to avoid slavery and human trafficking for the financial year ending 2017.

Jan Hilger

Global Head of Supply Chain