Privacy policy

Privacy policy

Privacy Policy

1) Information about the collection of personal data and contact details of the person responsible

1.1 We are pleased that you are visiting our website and thank you for your interest. In the following we will inform you about the handling of your personal data when using our website. Personal data are all data with which you can be personally identified.

1.2 The person responsible for data processing on this website within the meaning of the General Data Protection Regulation (GDPR) is Jana Ginglseder, Jana Leyla Designs, Emil-Zimmermann-Allee 24a, 45897 Gelsenkirchen, Deutschland, Tel.: 017632118029, E-Mail: info@janaleyladesigns.com. The person responsible for the processing of personal data is the natural or legal person who, alone or together with others, decides on the purposes and means of processing personal data.

1.3 For security reasons and to protect the transmission of personal data and other confidential content (e.g. orders or inquiries to the person responsible), this website uses an SSL or TLS encryption. 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 informational purposes 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, which is technically necessary for us to display the website to you:

  • Our visited website
  • Date and time at the time 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 anonymous form)

 

Processing takes place in accordance with Art. 6 Para. 1 lit. f GDPR based on 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 retrospectively if there are concrete indications of illegal use.

3) Hosting & Content-Delivery-Network

Hosted by Shopify
We use the shop system of the service provider Shopify International Limited, Victoria Buildings, 2nd floor, 1-2 Haddington Road, Dublin 4, D04 XN32, Ireland ("Shopify"), for the purpose of hosting and displaying the online shop on the basis of a Processing on our behalf. All data collected on our website is processed on Shopify's servers. As part of the aforementioned Shopify services, data can also be processed in the context of further processing on behalf of Shopify Inc., 150 Elgin St, Ottawa, ON K2P 1L4, Canada, Shopify Data Processing (USA) Inc., Shopify Payments (USA) Inc . or Shopify (USA) Inc. In the event that data is transmitted to Shopify Inc. in Canada, the European Commission's adequacy decision ensures the appropriate level of data protection. Further information on data protection from Shopify can be found on the following website: https://www.shopify.de/legal/datenschutz
Further processing on servers other than the aforementioned from Shopify will only take place within the framework communicated below.

4) Cookies

In order to make visiting 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 device. Some of the cookies we use are deleted again after the end of the browser session, i.e. after you close your browser (so-called session cookies). Other cookies remain on your device and enable your browser to be recognized the next time you visit (so-called 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. Persistent cookies are automatically deleted after a specified period, which can differ depending on the cookie. The duration of the respective cookie storage can be found in the overview of the cookie settings of your web browser.

In some cases, cookies are used to simplify the ordering process by saving settings (e.g. remembering the contents of a virtual shopping cart for a later visit to the website). If personal data is also processed by individual cookies we use, processing takes place in accordance with Art. 6 Para. 1 lit. b GDPR either for the execution of the contract, according to Art. 6 Para. 1 lit. a GDPR in the case of a given consent or in accordance with Art. 6 Para. 1 lit. 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.

Please note that you can set your browser so that you are informed about the setting of cookies and can decide individually whether to accept them or to exclude the acceptance of cookies for certain cases or in general. Each browser differs in the way it manages cookie settings. This is described in the help menu of every browser, which explains how you can change your cookie settings. You can find these for the respective browser under the following links:

Internet Explorer: https://support.microsoft.com/de-de/help/17442/windows-internet-explorer-delete-manage-cookies
Firefox: https://support.mozilla.org/de/kb/cookies-erlauben-und-ablehnen
Chrome: https://support.google.com/chrome/answer/95647?hl=de&hlrm=en
Safari: https://support.apple.com/de-de/guide/safari/sfri11471/mac
Opera: https://help.opera.com/de/latest/web-preferences/#cookies

Please note that if you do not accept cookies, the functionality of our website may be restricted.

5) Contact

5.1 Chatra (Roger Wilco LLC)
This website uses technologies from Roger Wilco LLC, Millen, White, Zelano & Branigan, Jeff Cohen, 2200 Clarendon Blvd., Suite 1400A, Arlington, VA 22201, USA (www.chatra.io) to collect pseudonymised data for the purpose of web analysis and to operate the live chat system, which is used to answer live support inquiries, collected and stored. Usage profiles can be created from this pseudonymized data under a pseudonym. Cookies can be used. Cookies are small text files that are stored locally in the cache of the visitor's Internet browser. Among other things, the cookies enable the Internet browser to be recognized. If the information collected in this way is related to a person, it is processed in accordance with Article 6 (1) (f) GDPR on the basis of our legitimate interest in effective customer service and the statistical analysis of user behavior for optimization purposes.
The data collected with the Chatra technologies will not be used to personally identify the visitor to this website and will not be merged with personal data about the bearer of the pseudonym without the separately given consent of the person concerned. In order to avoid the storage of Chatra cookies, you can set your internet browser so that cookies can no longer be stored on your computer in the future or cookies that have already been stored are deleted. Switching off all cookies can, however, mean that some functions on our website can no longer be carried out. You can deactivate data collection and storage for the purpose of creating a pseudonymised user profile at any time with effect for the future by sending us your objection informally by e-mail to the e-mail address given in the legal notice. The purpose and scope of the data collection and the further processing and use of the data by Chatra as well as your related rights and setting options to protect your privacy can be found in Chatra's data protection information: https://chatra.io/privacy-policy/

5.2 When you contact us (e.g. using the contact form or email), 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 answering your request or for establishing contact and the associated technical administration. The legal basis for the processing of this data is our legitimate interest in answering your request in accordance with Art. 6 Para. 1 lit. f GDPR. If your contact is aimed at concluding a contract, the additional legal basis for processing is Art. 6 Para. 1 lit. b GDPR. Your data will be deleted after your request has been processed. This is the case if it can be inferred from the circumstances that the matter in question has been finally clarified and provided that there are no statutory retention requirements.

6) Data processing when opening a customer account and for contract processing

According to Art. 6 Para. 1 lit. 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. You can delete your customer account at any time and send a message to the above. Address of the person responsible. We save and use the data you have provided to process the contract. After the contract has been fully processed or your customer account has been deleted, your data will be blocked with due regard to tax and commercial retention periods and deleted after these deadlines, unless you have expressly consented to further use of your data or we reserve the right to further use of your data as permitted by law has been.

7) Use of customer data for direct mail

- Sending newsletters via Shopify email
Our e-mail newsletters are sent via Shopify Email, a service provided by Shopify International Limited, Victoria Buildings, 2nd Floor, 1-2 Haddington Road, Dublin 4, D04 XN32, Ireland (“Shopify”), to which we send your Pass on the data provided when registering for the newsletter. This transfer takes place in accordance with Art. 6 Para. 1 lit. f GDPR and serves our legitimate interest in the use of an effective, secure and user-friendly newsletter system. The data you enter for the purpose of receiving the newsletter (e.g. email address) are generally stored on Shopify's servers in the EU.
As part of the aforementioned Shopify services, data can also be processed in the context of further processing on behalf of Shopify Inc., 150 Elgin St, Ottawa, ON K2P 1L4, Canada, Shopify Data Processing (USA) Inc., Shopify Payments (USA) Inc. or Shopify (USA) Inc. In the event that data is transmitted to Shopify Inc. in Canada, the European Commission's adequacy decision guarantees the appropriate level of data protection.
Shopify uses this information to send and statistically evaluate the newsletters on our behalf. For the evaluation, the e-mails sent can contain so-called web beacons or tracking pixels, which represent one-pixel image files that are stored on our website. In this way it can be determined whether a newsletter message has been opened and which links have been clicked. Technical information is also recorded (e.g. time of access, IP address, browser type and operating system). The data is collected exclusively in pseudonymised form and is not linked to your other personal data; direct personal reference is excluded. This data is used exclusively for the statistical analysis of newsletter campaigns. The results of these analyzes can be used to better adapt future newsletters to the interests of the recipients. If you want to object to the data analysis for statistical evaluation purposes, you must unsubscribe from the newsletter.

Furthermore, Shopify can use this data according to Art. 6 (1) point f GDPR even on the basis of its own legitimate interest in the demand-oriented design and optimization of the service as well as for market research purposes, for example to determine from which countries recipients come. However, Shopify does not use the data of our newsletter recipients to write to them itself or to pass the data on to third parties.
We have concluded an order processing agreement with Shopify, with which we oblige Shopify to protect our customers' data and not to pass them on to third parties.
You can view Shopify's privacy policy here: https://www.shopify.de/legal/datenschutz.

8) Data processing for order processing

8.1 - Transmission of image files for order processing by email
On our website, we offer customers the opportunity to commission the personalization of products by sending image files by email. The submitted image is used as a template for personalizing the selected product.
The customer can send one or more image files from the memory of the device used to us via the email address given on the website. We then collect, save and use the files transmitted in this way exclusively to produce the personalized product in accordance with the respective service description on our website. If the transmitted image files are passed on to special service providers for the preparation and processing of the order, you will be explicitly informed about this in the following paragraphs. Any further transfer does not take place. If the transmitted files or the digital motifs contain personal data (in particular images of identifiable persons), all processing operations just mentioned are carried out exclusively for the purpose of processing your online order in accordance with Art. 6 Para. 1 lit. b GDPR. After the order has been processed, the transmitted image files are automatically and completely deleted.

8.2 To process your order, we work together with the following service provider (s) who support us in whole or in part in the execution of concluded contracts. Certain personal data is transmitted 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 as part of the 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 as part of the payment processing, if this is necessary for the payment processing. If payment service providers are used, we will explicitly inform you about this below. The legal basis for forwarding the data is Article 6 Paragraph 1 lit. b GDPR.

8.3 Use of payment service providers (payment services)

- Apple Pay
If you choose the "Apple Pay" payment method from Apple Distribution International (Apple), Hollyhill Industrial Estate, Hollyhill, Cork, Ireland, the payment will be processed using the "Apple Pay" function on your device operated with iOS, watchOS or macOS by debiting a payment card stored with "Apple Pay". Apple Pay uses security features built into your device's hardware and software to protect your transactions. To approve a payment, it is necessary to enter a code that you previously specified and to verify it using the “Face ID” or “Touch ID” function of your device.
For the purpose of payment processing, the information you provided during the ordering process, along with the information about your order, will be passed on to Apple in encrypted form. Apple then encrypts this data again with a developer-specific key before the data is transmitted to the payment service provider of the payment card stored in Apple Pay to carry out the payment. The encryption ensures that only the website from which the purchase was made can access the payment details. After the payment has been made, Apple will send your device account number and a transaction-specific, dynamic security code to the original website to confirm the success of the payment.
If personal data is processed in the described transmissions, the processing takes place exclusively for the purpose of payment processing in accordance with Art. 6 Para. 1 lit. b GDPR.
Apple maintains anonymized transaction data, including the approximate purchase amount, approximate date and time, and whether the transaction was successfully completed. The anonymization completely rules out any personal reference. Apple uses the anonymized data to improve "Apple Pay" and other Apple products and services.
When you use Apple Pay on the iPhone or Apple Watch to complete a purchase made through Safari on the Mac, the Mac and the authorization device communicate over an encrypted channel on the Apple servers. Apple does not process or store any of this information in a format that can be used to identify you personally. You can turn off the ability to use Apple Pay on your Mac in your iPhone's settings. Go to Wallet & Apple Pay and turn off Allow Payments on Mac.
Further information on data protection with Apple Pay can be found at the following Internet address: https://support.apple.com/de-de/HT203027
- Google Pay
If you choose the "Google Pay" payment method from Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland ("Google"), the payment is processed via the "Google Pay" application of yours with at least Android 4.4 ("KitKat") operated mobile device with an NFC function by debiting a payment card stored with Google Pay or a payment system verified there (e.g. PayPal). To release a payment via Google Pay in the amount of more than € 25, you must first unlock your mobile device using the verification measure set up in each case (such as face recognition, password, fingerprint or sample).
For the purpose of payment processing, the information you provided during the ordering process, along with information about your order, will be passed on to Google. Google then transmits your payment information stored in Google Pay in the form of a unique transaction number to the original website, with which a successful payment is verified. This transaction number does not contain any information about the real payment data of your means of payment stored with Google Pay, but is created and transmitted as a one-time valid numeric token. For all transactions via Google Pay, Google only acts as an intermediary for processing the payment process. The transaction is carried out exclusively in the relationship between the user and the starting website by debiting the means of payment stored with Google Pay.
If personal data is processed in the described transmissions, the processing takes place exclusively for the purpose of payment processing in accordance with Art. 6 Para. 1 lit. b GDPR.
Google reserves the right to collect, store and evaluate certain process-specific information for every transaction made via Google Pay. This includes the date, time and amount of the transaction, the location and description of the dealer, a description of the goods or services purchased by the dealer, photos that you included in the transaction, the name and email address of the seller and buyer or of the sender and recipient, the payment method used, your description of the reason for the transaction and, if applicable, the offer associated with the transaction.
According to Google, this processing takes place exclusively in accordance with Art. 6 Paragraph 1 lit. f GDPR.
Google also reserves the right to merge the processed data with other information that is collected and stored by Google when other Google services are used.
The terms of use of Google Pay can be found here:
https://payments.google.com/payments/apis-secure/u/0/get_legal_document?ldo=0&ldt=googlepaytos&ldl=de
Further information on data protection with Google Pay can be found at the following Internet address:
https://payments.google.com/payments/apis-secure/get_legal_document?ldo=0&ldt=privacynotice&ldl=de
- Klarna
If a Klarna payment service is selected, the payment will be processed by Klarna Bank AB (publ) [https://www.klarna.com/de], Sveavägen 46, 111 34 Stockholm, Sweden (hereinafter "Klarna"). In order to enable the processing of the payment, your personal data (first and last name, street, house number, zip code, city, gender, email address, telephone number and IP address) as well as data related to the order are stored (e.g. invoice amount, article, type of delivery) passed on to Klarna for the purpose of identity and credit checks, provided that you have expressly consented to this in accordance with Article 6 (1) (a) GDPR as part of the ordering process. You can see here which credit agencies your data can be forwarded to:
https://cdn.klarna.com/1.0/shared/content/legal/terms/0/de_de/credit_rating_agencies
The credit report can contain probability values (so-called score values). As far as score values are included in the result of the credit report, they are based on a scientifically recognized mathematical-statistical procedure. The calculation of the score values includes, but is not limited to, address data. Klarna uses the information received about the statistical probability of a payment default for a balanced decision on the establishment, implementation or termination of the contractual relationship.
You can revoke your consent at any time by sending a message to the person responsible for data processing or to Klarna. However, Klarna may still be entitled to process your personal data if this is necessary for contractual payment processing.
Your personal details are processed in accordance with the applicable data protection regulations and in accordance with the information in Klarna’s data protection regulations for data subjects based in Germany https://cdn.klarna.com/1.0/shared/content/legal/terms/0/de_de/privacy
or for data subjects based in Austria https://cdn.klarna.com/1.0/shared/content/legal/terms/0/de_at/privacy
treated.
- Paypal
When paying via PayPal, credit card via PayPal, direct debit via PayPal or - if offered - "purchase on account" or "installment payment" via PayPal, we give your payment data to PayPal (Europe) S.a.r.l. as part of the payment processing. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg (hereinafter "PayPal"). The transfer takes place in accordance with Art. 6 Para. 1 lit. b GDPR and only insofar as this is necessary for payment processing.
PayPal reserves the right to carry out a credit check for the payment methods credit card via PayPal, direct debit via PayPal or - if offered - "purchase on account" or "payment in installments" via PayPal. For this purpose, your payment data may be passed on to credit agencies in accordance with Article 6 (1) (f) GDPR on the basis of PayPal's legitimate interest in determining your solvency. PayPal uses the result of the credit check with regard to the statistical probability of default for the purpose of deciding whether to provide the respective payment method. The credit report can contain probability values (so-called score values). As far as score values are included in the result of the credit report, they are based on a scientifically recognized mathematical-statistical procedure. The calculation of the score values includes, but is not limited to, address data. For more information on data protection, including the credit agencies used, please refer to PayPal's privacy policy: https://www.paypal.com/de/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.
- Shopify Payments
We use the payment service provider "Shopify Payments", 3rd Floor, Europa House, Harcourt Building, Harcourt Street, Dublin 2. If you choose a payment method offered by the payment service provider Shopify Payments, the payment will be processed by the technical service provider Stripe Payments Europe Ltd. , 1 Grand Canal Street Lower, Grand Canal Dock, Dublin, Ireland, to whom we will transmit the information you provided during the ordering process, along with information about your order (name, address, account number, bank code, possibly credit card number, invoice amount, currency and transaction number) in accordance with Art. 6 Para. 1 lit. b GDPR. Your data will only be passed on for the purpose of processing payments with Stripe Payments Europe Ltd. and only insofar as it is necessary for this. You can find more information on data protection at Shopify Payments at the following Internet address: https://www.shopify.com/legal/privacy.
Data protection information about Stripe Payments Europe Ltd. can be found here: https://stripe.com/de/privacy
- SOFORT
If the payment method "SOFORT" is selected, the payment will be processed by the payment service provider SOFORT GmbH, Theresienhöhe 12, 80339 Munich, Germany (hereinafter "SOFORT"), to whom we will send the information you provided during the ordering process along with the information about your order in accordance with Art. 6 Para. 1 lit.b GDPR. Sofort GmbH is part of the Klarna Group (Klarna Bank AB (publ), Sveavägen 46, 11134 Stockholm, Sweden). Your data is passed on exclusively for the purpose of processing payments with the payment service provider SOFORT and only to the extent that it is necessary for this. You can find more information about SOFORT's data protection provisions at the following Internet address: https://www.klarna.com/sofort/datenschutz.

9) Rights of the data subject

9.1 The applicable data protection law grants you comprehensive rights of data subjects (information and intervention rights) to the person responsible with regard to the processing of your personal data, about which we inform you below:

  • Right to information in accordance with Art. 15 GDPR: In particular, you have a right to information about your personal data processed by us, the processing purposes, the categories of personal data processed, the recipients or categories of recipients to whom your data has been or will be disclosed, the planned storage period or the criteria for determining the storage period, the existence of a right to correction, deletion, restriction of processing, objection to processing, complaint to a supervisory authority, the origin of your data, if we did not collect them from you, the existence of automated decision-making including profiling and, if necessary, meaningful information about the logic involved and the scope and the intended effects of such processing, as well as your right to be informed about the guarantees pursuant to Art. 46 GDPR when your data is forwarded in third countires exist;
  • Right to correction according to Art. 16 GDPR: You have the right to immediate correction of incorrect data concerning you and / or completion of your incomplete data stored by us;
  • Right to deletion in accordance with Art. 17 GDPR: You have the right to request the deletion of your personal data if the requirements of Art. 17 Paragraph 1 GDPR are met. However, this right does not exist in particular if the processing is necessary to exercise the right to freedom of expression and information, to fulfill a legal obligation, for reasons of public interest or to assert, exercise or defend legal claims;
  • Right to restriction of processing in accordance with Art. 18 GDPR: You have the right to request that the processing of your personal data be restricted as long as the correctness of your data is checked, if you refuse to delete your data due to inadmissible data processing and instead request the request restriction of the processing of your data if you need your data to assert, exercise or defend legal claims after we no longer need this data after the purpose has been achieved or if you have objected for reasons of your particular situation, as long as it is not certain whether our legitimate reasons outweigh;
  • Right to information in accordance with Art. 19 GDPR: If you have asserted the right to correction, deletion or restriction of processing against the person responsible, the person responsible is obliged to notify all recipients to whom the personal data concerning you have been disclosed, unless this proves to be impossible or involves a disproportionate effort. You have the right to be informed about these recipients.
  • Right to data portability in accordance with Art. 20 GDPR: You have the right to receive your personal data that you have provided to us in a structured, common and machine-readable format or to request that it be transferred to another person responsible, insofar as this is technically feasible;
  • Right to revoke consent given in accordance with Art. 7 Para. 3 GDPR: You have the right to revoke your consent to the processing of data at any time with effect for the future. If you withdraw your consent, we will immediately delete the data concerned, unless further processing can be based on a legal basis for processing without consent. Withdrawing your consent does not affect the legality of the processing carried out on the basis of your consent up to the point of withdrawal;
  • Right to lodge a complaint in accordance with Art. 77 GDPR: If you consider that the processing of your personal data violates the GDPR, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your place of residence, your place of work or the place of the alleged infringement.

9.2 RIGHT TO OBJECT

IF WE PROCESS YOUR PERSONAL DATA IN THE CONTEXT OF A COMPARISON OF INTERESTS DUE TO OUR PREVAILING LEGITIMATE INTEREST, YOU HAVE THE RIGHT TO OBJECT TO THIS PROCESSING AT ANY TIME FOR REASONS ARISING FROM YOUR SPECIAL SITUATION, WITH EFFECT FOR THE FUTURE.

IF YOU USE YOUR RIGHT TO OBJECT, WE WILL TERMINATE THE PROCESSING OF THE DATA IN QUESTION. HOWEVER, WE RESERVE THE RIGHT TO FURTHER PROCESSING IF WE CAN PROVE THAT THERE ARE BINDING REASONS FOR PROCESSING WHICH ARE WORTHY OF PROTECTION AND WHICH OVERWEIGH YOUR INTERESTS, FUNDAMENTAL RIGHTS AND FUNDAMENTAL AND FREDDOM RIGHTS, OR IF THE PROCESSING SERVES THE PURPOSE OF ASSERTING, EXERCISING OR DEFENDING LEGAL CLAIMS.

IF YOUR PERSONAL DATA ARE PROCESSED BY US FOR THE PURPOSE OF DIRECT MARKETING, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF YOUR PERSONAL DATA FOR THE PURPOSE OF SUCH MARKETING. YOU CAN OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA AS DESCRIBED ABOVE. IF YOU USE YOUR RIGHT OF OBJECTION, WE WILL TERMINATE THE PROCESSING OF THE DATA CONCERNED FOR DIRECT MARKETING PURPOSES.

10) Duration of storage of personal data

The duration of the storage of personal data is based on the respective legal basis, the processing purpose and - if relevant - additionally based on the respective statutory retention period (e.g. commercial and tax retention periods).

When processing personal data on the basis of express consent in accordance with Art. 6 Para. 1 lit. a GDPR, this data is stored until the person concerned revokes his consent.

Are there statutory retention periods for data that are required within the framework of legal or similar obligations on the basis of Art. 6 Para. 1 lit. b GDPR are processed, these data are routinely deleted after the retention periods have expired, provided that they are no longer required for contract fulfillment or contract initiation and / or on our part there is no legitimate interest in further storage.

When processing personal data on the basis of Art. 6 Para. 1 lit. f GDPR, this data is stored until the person concerned exercises his right of objection according to Art. 21 Para. 1 GDPR, unless we can prove compelling reasons for processing that outweigh the interests, rights and freedoms of the person concerned or the processing serves to assert, exercise or defend legal claims.

When processing personal data for the purpose of direct advertising on the basis of Art. 6 Para. 1 lit. f GDPR, this data is stored until the person concerned exercises his right of objection according to Art. 21 Para. 2 GDPR.

Unless otherwise stated in the other information in this declaration on specific processing situations, stored personal data will otherwise be deleted when they are no longer necessary for the purposes for which they were collected or otherwise processed.