Privacy policy

Privacy policy

Custombella Data protection statement

At: 012/2018

This Data Protection Declaration gives you an overview of how Custombella processes your data. It applies to all websites, apps and other benefits and services offered by Custombella.

How you can read these Data Protection Declarations: We offer you various options for reading this Data Protection Declarations. Firstly, you can find very basic information in this section. Then we have sorted this Data Protection Declaration into topics relevant for you and divided it accordingly into individual chapters.

We have prefixed each chapter with a short overview. This overview briefly summarises the content of the chapter. If you just want a quick high-level overview of all data processing, it is advisable to read the overviews. If you want to familiarise yourself with the details, you can click on “more” under the relevant overview. The full content of the chapter will then be displayed.

We have avoided cross-references wherever possible. That way you get all information coherently explained, regardless of which chapter you are currently reading. If you read this Data Protection Declaration from start to finish, you may find that parts of the text are repeated. We were unable to avoid a few cross-references. For example, we summarised all country-specific data processing in a single chapter and always refer to this chapter when discussing country-specific data processing.

Which services and offers this Data Protection Declaration applies to: Custombella processes your data in a similar way for most of our services. This Data Protection Declaration therefore applies to all benefits and services which we offer our European customers. This is true regardless of whether we do this via a website, an app, in transactions, on the phone, at events or via social networks or other channels. For ease of comprehension, we use the term “services” to summarise this “normal case”.

There are, however, also exceptional services where we process your data differently or for particular purposes. This may be due to the nature of a service or country-specific requirements. When we are referring to these cases (that is “deviations from the normal case”), we call them “service-specific” or “country-specific”.

Finally, you should also bear in mind that Custombella is not just a single company. Custombella is a group and this consists of multiple companies. Not all of these companies offer you services or process your data. Where we refer below to “Custombella”, “we” or “us”, we mean the responsible companies within Custombella Group which process your data.

1. Which data does Custombella process?

Custombella offers you a wide range of services, which you can also use in a wide range of ways. Depending on whether you contact us online, by phone or otherwise and on which services you use, various data from different sources may come into play. Much of the data we process is provided by you yourself when you use our services or contact us, for example when you register and provide your name or email address or address. We do, however, also receive technical device and access data which is automatically collected when you interact with our services. This may, for example, be information on which device you are using. We collect further data using our own data analyses (e.g. within the framework of market research studies and customer evaluations). We may also receive data on you from third parties, for example for credit rating agencies and payment service providers.

When we talk about “your data”, we are referring to personal data. This includes all information which allows us to identify you straight away or by combining it with other information. Examples: Your name, your telephone number, your customer number, order numbers or your email address. All information which cannot be used to identify you (even by combining it with other data) is classified as non-personal data. Non-personal data is also referred to as anonymous data. If we combine your personal data with anonymous data, all the data in this record counts as personal data. If we delete the personal data from a piece of information or a record on your person, the remaining data in this record no longer counts as personal data. This procedure is referred to as anonymisation. The following generally applies: If we request that you share particular personal information with us, you may of course refuse to do this. You can decide which information you share with us. We may, however, be unable to provide you with the desired services (at least not optimally). For example, you cannot have a package delivered without giving a delivery address. If particular information is required in connection with a service (mandatory information), we will inform you by marking it accordingly.

1.1 Profile information

Profile information is personal and demographic information on your person (so-called master data), along with your individual interests, which you share with us when registering for a customer account. Your profile data includes, for example:

  • Your first and last names
  • Your contact details
  • Your preferences, e.g. in relation to brands, product types or styles
  • Demographic information such as your gender, age and place of residence

Mandatory information is usually your name, your email address and a password you choose yourself. Your email address and the password will later constitute your login details.

Other mandatory information may also be required for the use of access-restricted, fee-based or personalised services, such as your date of birth or your title (e.g. in order to transfer you to the relevant Custombella shop page for your gender) or your favourite brands and clothing styles.

Profile data may also include further information on your person and your interests. These may be collected in the process of registering for the service, or only subsequently. This is the case, for example, if you later add voluntary information to your profile or you wish to use your customer account to register for a service which requires additional mandatory information.

1.2 Contact details

If you contact us, we collect your data. Depending on how you contact us (e.g. by phone or by email), your contact details may include your name, postal addresses, telephone numbers, fax numbers, email addresses, detail on your social network profiles (for example we receive your Facebook ID if you contact us via Facebook), user names and similar contact details.

1.3 Shopping information

If you order something from Custombella or shop on site, for example at a Custombella Outlet Store, we collect your shopping data. Depending on the type of purchase and processing status, shopping data may include the following information:

  • Order number
  • Details on the purchased items (name, size, colour, price etc.)
  • Payment method information
  • Delivery and billing addresses
  • Messages and communication relating to purchases (e.g. notice of revocation, complaints and messages to customer service)
  • Delivery and payment status, e.g. “completed” or “dispatched”
  • Return status, e.g. “successfully completed”
  • Information on service providers involved in executing the contract (for order purchasing perhaps shipment numbers of parcel services)

1.4 Payment details

We offer you the common payment methods in online retail - especially advance payment, credit card, PayPal, invoice or even by phone during opening hours. We collect the payment details shared by you in order to execute the payment. We receive further payment details from external payment service providers and credit agencies which we work with in executing payments and carrying out credit checks. We only forward information to our payment service providers which is necessary for processing payment.

Payment details include:

  • Preferred payment method
  • Billing addresses
  • IBAN and BIC or account number and sort code
  • Credit card details
  • Creditworthiness data

The payment details also include other information directly connected to payment processing and credit checking. This applies, for example, to information which external payment service providers use for identification such as your PayPal ID (if you are paying with PayPal).

Creditworthiness data consists of our own records on your previous payment behaviour towards all Custombella Group companies and of score values which we collect on you from external credit agencies. Creditworthiness data makes statements on a person’s estimated capacity and willingness to pay. This helps companies to avoid defaults which result when customers cannot fulfil their payment obligations or cannot do so in good time. Taking creditworthiness data when choosing payment methods is also intended to prevent us offering our customers payment methods which cannot be offered to them and our customers entering into payment obligations which they cannot fulfil themselves. Creditworthiness data is normally collected from so-called credit agencies. The credit agencies then use various information to calculate a so-called score value which takes into account existing payment obligations and any previous defaults. Score values are statistically justified estimates of the future risk of a person defaulting and are represented as a numerical value, such as a percentage. We only have limited influence on processing of data by external credit agencies (e.g. if we provide credit agencies information on payment obligations which have not been fulfilled).

Cooperation with external payment service providers and credit agencies is on a country-specific basis, in order to take country-specific features and requirements into account. Under Country-specific information you can find information on which external payment service providers and credit agencies we work with in which countries. There you can also find special privacy policies which we provide you with on behalf of the relevant payment service providers and credit agencies.

1.5 Interests information

When you interact with our services, data arises which we use to find out which content, topics, products, product types, brands or styles you are interested in. For example, we can use shopping data, wish list content and your age (if this information is available to us) and comparison with users with similar features to find out which styles and product categories you are interested in. Thus, we can show the products which will probably be most relevant to you first the next time you perform a search.

Along with the interests you have directly shared with us, we can also derive your interests from other data we have collected. If, for example, you repeatedly visit a particular area of the Custombella shop, we can extrapolate your interests from your access data by means of usage analysis (e.g. we can deduce that you might be interested in sport if you frequently visit the category “sportswear” or order products from this category).

For this purpose, we also receive demographic information and statistics on our users from our external advertising partners (such as age, gender, region), as well as device and access data and interests. We take care that our advertising partners only provide Berlimoni with aggregate, encrypted and anonymous data, so that we cannot assign the data to any particular person, especially any particular user. This information may help us to understand our users better, perhaps within the framework of customer structure analyses and user segmentation.

You can find further information on the processing of your data for advertising purposes under “How does Custombella use my data for marketing?”.

1.6 Messages, conversation content

If you communicate with us or other users regarding products (e.g. product evaluations) and other topics by phone, post, social media, contact forms or any other medium, we collect the content of your messages.

We may forward your messages to the office responsible for your concerns, perhaps to partner companies or manufacturers. If your messages are forwarded to another company (e.g. if you provide us with feedback on the manufacturer of a product), you of course have the option to tell us that the data should only be used by Custombella. If so, we will not forward your information to the responsible office, or will only do so without your personal information, provided that your concerns can be processed in this way.

If you transmit messages to us for other users via functions provided for this purpose (e.g. product evaluations), we may publish these within the scope of our services.

Custombella also uses social network services such as Facebook, Instagram, linkedin and Twitter to communicate with customers and users. We use these popular platforms to offer you further contact and information options beyond our in-house communication channels. Please bear in mind, however, that we do not have any influence on the terms of use for social networks and the services they offer, and only limited influence on their data processing. We therefore ask you to carefully check which personal data you share with us via social networks. We cannot influence the behaviour of social media operators, other users or third parties who may work with the operators of the social networks or also use these services.

1.7 Social network data

Social media functions may be integrated into Custombella’s services. These may include messenger services and so-called social plug-ins or social logins, such as “login with Facebook”. If you activate or use these functions and are a member of the relevant social network, we may receive data from their respective operators which allows us to identify you. We usually receive the following data from social networks:

  • your public profile information (e.g. name, profile picture)
  • Information on the type of device you are using
  • the account ID of your profile with the relevant network (e.g. Facebook ID)

We will also not receive any data from the social network providers which could be used to identify or contact you unless you provide your consent.

In connection with advertising via social networks we generally only receive general demographic and interest-related information to make our adverts more efficient, e.g. that a particular advert was clicked on by a man from Glasgow between the ages of 25 and 34 and interested in shopping and clothes. This information and these estimates come from the operator of the social network.

You can find more detailed information in the relevant providers’ terms of use and privacy policies.

Please also take into account the notice on the processing of social network data in connection with social network functions under “Info on websites and apps”.

Custombella currently uses Facebook’s Messenger service and social plug-ins/logins from the following social networks:

  • Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA (“Facebook”). You can find the link to Facebook’s Data Protection Declaration here: Facebook’s privacy policy.
  • Twitter Inc., 795 Folsom St., Suite 600, San Francisco, CA 94107, USA (“Twitter”). You can find the link to Twitter’s privacy policy here: Twitter’s privacy policy.
  • Pinterest Inc., 651 Brannan Street, San Francisco, CA 94103, USA (“Pinterest”). You can find the link to Pinterest’s privacy policy here: Pinterest’s privacy policy.

1.8 Site data

For particular purposes, we also collect data on your device’s current location when you use our services. Two different technologies are used for this.

If you approve your device’s location services for an app, a website or another online service by Custombella, Custombella processes the location data collected by your device and provided to us in order to provide you with location-specific services.


Some of our apps show you shops in your area or suggest products which correspond to your current location.

If you allow a Custombella app to access your device’s location services, your location may be regularly processed by Custombella (e.g. even if you are not currently using the app). This serves to improve the user experience, for example by loading location-dependent content faster when you use the app at your location, or displaying location-based push notifications. We do not use this data to produce any motion profiles. You can obtain further information on location-based services if required.

We also collect location data derived from your device’s IP address (down to the city level). An anonymised IP address shortened to three characters is used for this purpose. Therefore, this cannot be used to identify your internet connection or device.

What are IP addresses?

Each device connected to the internet must be assigned a multiple-character, unambiguous number (example: This is referred to as an IP address.

The first three characters of an IP address are usually assigned to a particular region or a particular internet provider. The approximate location of the internet connection can therefore be derived from the IP address.

This procedure (so-called geolocalisation) is used by us and many other online shops, for example to identify fraud and suspicious orders (e.g. it may be suspicious in particular situations if an order from your customer account uses an IP address from a country where you have never previously made any orders).

1.9 Photos and other personal content

Some of our service-specific applications allow you to share photos and other personal content with us or other users, in order to communicate with us or other users or to personalise services (e.g. by uploading a profile picture, using the Custombellai's app’s photo search or communicating with a stylist).

1.10 Information for campaigns and surveys

If you take part in a campaign (e.g. competition) or survey (e.g. customer satisfaction survey for market research purposes) offered by Custombella, we ask you for personal information.

For example, if you take part in a competition we generally ask you for your name and email address, so that we can inform you if you win and to ensure that each participant only takes part in the competition once.

We may ask you for further information for some campaigns and surveys. This may be the case, for example, if we carry out a campaign with a partner and the partner needs information on you in order to make the prize available to you. In such cases we will, however, always inform you separately about the information required and how we use it.

1.11 Device and access data

When using online and mobile services, it is inevitable that technical data will arise and be processed, in order to provide the functions and content offered and to display them on your device. We refer to this data collectively as “device and access data”. Device and access data arises each time you use an online and mobile service. It doesn’t matter who the provider is. Device and access data arise, for example, when you use:

  • Websites
  • Apps
  • Email newsletters (i.e. when your newsletter interaction is captured)
  • Location-based services

On the one hand, Custombella collects device and access data from online and mobile services offered by Custombella itself (e.g. Custombella shop). On the other, Custombella may receive device and access data from online and mobile services provided by other companies & advertising networks (e.g. the “Google advertising network”). You can find further information under “How does Custombella use my data for advertising?”.

Device and access data includes the following categories:

  • General device information, such as information on the device type, operating system version, configuration settings (e.g. language settings, system authorisations), information on internet connection (e.g. name of the mobile data network, connection speed) and on the app used (e.g. name and version of the app).
  • Identification data (IDs), such as session IDs, cookie IDs, unambiguous device ID numbers (e.g. Google advertising ID, Apple Ad ID), third party account IDs (if you use social plug-ins or social logins or pay by PayPal) and other common internet technologies, to facilitate recognition of your web browser, your device or a particular app installation.


If you activate the push notification service in a Custombella app, you will be provided with a randomly generated, unambiguous push ID. We send the push ID together with the push notifications aimed at you to the push server, so that the latter can address the notification to the right recipient, that is to your device.

  • Access data automatically transmitted by apps and web browsers whenever you access web servers and databases (within the framework of so-called HTTP requests). This is standardised information on the required content (such as the name and file type of a retrieved file) as well as further information on server access (such as amount of data transferred and error codes), on your device (e.g. device type, operating system, software versions, device identifications, IP address, the site previously visited and the time of access).

2. What does Custombella use my data for?

Custombella processes your data in accordance with all applicable data protection laws. Of course, we observe the principles of data protection law for the processing of personal data. We therefore generally only process your data for the purposes explained to you in this Data Protection Declaration or shared when we collect the data. These are mainly purchase processing and the provision, personalisation and development as well as security of our services. We also use your data within the framework of the strict European data protection law, but also for other purposes such as product development, scientific research (especially in the areas of machine learning, artificial intelligence and deep learning) and market research, for the optimisation of business processes, the needs-based design of our services and personalised advertising.

In this chapter, we also inform you of the legal basis on which we process data for the individual purposes. Depending on the legal basis for our processing of your data, you may have additional data protection rights alongside your permanent rights such as the right to information. For example, in individual cases you have the right to object to the processing of your data. You can find further information under “Which data protection rights do I have?”

2.1 Purchase processing and provision of online, local and personalised services

We process your data in the necessary scope to fulfil contracts and to provide and execute further services requested by you, as described in this Data Protection Declaration. The purposes of the necessary data processing therefore depend on the purpose of the contract agreed with you (including our General Terms and Conditions and any service-specific terms and conditions or terms of use) or services requested by you. The most important purposes are:

  • The provision, personalisation and needs-based design of our services such as the Custombella shop (including their respective websites, apps and cross-device and cross-platform functions).
  • The provision of local services, e.g. in Custombella Outlet Stores and at events and trade fairs.
  • The execution of customer programmes such as Custombella Card.
  • The execution of purchase agreements and customer service including dispatch and payment processing, claim management as well as the processing of returns, complaints and warranty claims.
  • The provision of messages, reports, newsletters and other direct communication, insofar as these are an integral component of our contractual services or the services requested by you.


You can request email information on the availability of out-of-stock items in the Custombella shop.

In our apps you can request push-service information on particular events or offers and other subjects.

If you take part in our online shopping club Custombella Lounge, you will regularly receive our Custombella Lounge newsletter with information on current promotions.

  • The guarantee of the general security, operability and stability of our service including defence from attacks.
  • Non-promotional communication with you on technical, security-related and contractually relevant subjects (e.g. fraud warnings, account blocking or contractual changes)
  • The issuing, redemption, delivery of Custombella vouchers.
  • The execution of campaigns and competitions.

Legal basis:

Insofar as the purpose relates to the execution of a contract agreed with you or the provision of a service requested by you, the legal basis is Article 6 (1) b GDPR. Otherwise, the legal basis is Article 6 (1) f GDPR, whereby we may use your personal data for the above purposes if we deem it necessary to do so for our legitimate interests.

2.2 Shopping personalisation

We process your data for the provision of comfortable and useful services which correspond as well as possible to your needs and interests. Because the Custombella shop’s range encompasses hundreds of thousands of products and thousands of brands, it is necessary that we present our content and offers in a needs-based manner so that you can find products you are actually interested in. This requires a user-specific evaluation of the relevance of products and content.

To personalise shopping in the Custombella shop we use device and access data which we collect for usage analysis. Alongside this, we also use device and access data which we receive from advertising partners while you visit the Custombella shop. If you are logged in with your customer account while visiting the Custombella shop, we also use profile data, interest data and shopping data to personalise your shopping experience. We refer to this form of shopping personalisation as on-site optimisation. Only such shopping personalisation allows us to present you with suitable search results, product suggestions, style recommendations and other content corresponding to your actual interests. Without such shopping personalisation, as carried out today by many online shops as standard, your search for relevant products would be less convenient and more protracted and the utility of our range for you would be lower. Shopping personalisation does not, of course, prevent you from accessing all content. It does, however, allow you to see content which is more relevant to you more quickly.

Find out more

We have collected more details on the operating principle of Custombella’s websites and apps under “Shopping personalisation”.

You can find further details on the operating principle of personalised Custombella Services under “Personalised services”.

Legal basis:

The legal basis for the processing of your data for shopping personalisation within the framework of personalised services is Article 6 (1) b GDPR. The legal basis for the processing of your data within the framework of on-site optimisation is Article 6 (1) f GDPR, whereby our legitimate interests are in the above purposes.

2.3 Research, machine learning and artificial intelligence

We process the data collected on our customers for scientific research in the areas relevant to Custombella. This includes in particular the research areas of machine learning, artificial intelligence, natural language processing and deep learning. Research at Custombella concentrates on solutions to real, everyday online shopping problems and is meant to serve the improvement and development of the existing services range. In this way, for example, we can develop apps which can suggest products targeted to your interests and needs and recognise styles and assign products which correspond to your actual interests.

In doing this, of course, we observe recognised scientific data protection standards. This also means that we only process your data in summarised, anonymised or pseudonymised form for research purposes, for example by replacing all identifiable data such as your name with other values.

Find out more

You can find further information on the subject of research and science at Custombella research.

Research at Custombella includes the following purposes:

  • The development of machine learning procedures allowing estimates, prognoses and analysis of the needs and interests of our users.
  • The development of technical solutions for real customer problems which our specialist departments and fashion manufacturers encounter in day-to-day business (e.g. difficulties in finding suitable products, reducing the probability of bad buys, sizing).
  • The development of technical solutions for optimising business and logistics processes.
  • The development of technical solutions facilitating the improvement and development of shopping personalisation and fraud prevention.
  • The registration of patents and publication of specialist articles.
  • Participation in research communities and academic cooperation partners.


The size recommendations for shoes in the Custombella shop use a machine learning algorithm developed by Custombella Research. In developing the learning algorithm, Custombella Research has used shopping data with shoe orders, returns due to sizing and sizing information from various manufacturers. We used this to develop an intelligent size recommendation procedure for shoes in order to predict which shoe models are too large or too small.

Legal basis:

The legal basis for the processing of your data within the framework of the research purposes described above is Article 6 (1) f GDPR, whereby our legitimate interests are in the above purposes.

2.4 Fraud prevention, selection of payment methods and credit checks

Prevention of fraud

In order to combat the risk of data security breaches, data pertaining to users of our services is encrypted in transmission. This applies both to ordering and to registering for a customer account. For this we use the coding system SSL (Secure Socket Layer). Encryption prevents third parties from viewing the data. To provide additional protection from external attacks, we rely on special security technologies which constantly check our systems and identify and report anomalies. We also use technical and organisational measures to secure our systems against loss, destruction, unauthorised access or distribution of customer data by unauthorised persons. In this manner we wish to keep the risk of unauthorised access as low as possible, because protecting your data is our top priority. However, we - like other companies - cannot guarantee absolute protection.

Following registration for a customer account, Custombella transmits your name and your addresses as given in the profile to external credit agencies. This serves to ensure that you are actually registered and can be reached at the disclosed addresses. Typical indicators which - usually in combination - may increase the probability of attempted fraud include:

  • Your delivery address was changed shortly before the submission of the order and/or is in a region with increased risk of fraud.
  • Your order is particularly large and/or includes products which are subject to particularly high demand at present and/or are carried out at an unusual time for your region (e.g. at night).
  • The payment methods invoice or direct debit are used for the order.
  • There were suspicious login attempts on your account before the order was submitted, the pattern of which suggests automation.
  • Your customer account is used from a suspicious IP address.
  • Your customer account is used by an unknown or suspicious device.

If our security system suspects attempted fraud or an increased risk of fraud, the relevant procedure will be forwarded to the Custombella fraud team for manual investigation. Appropriate preventative measures will be taken in view of the risk of fraud (e.g. temporary blocking of the customer account or restriction of payment methods offered).

Legal basis:

If your data is processed to prevent fraud at your expense, the legal basis is Article 6 (1) b GDPR. This processing of your data otherwise occurs on the basis of Article 6 (1) f GDPR, based on our legitimate interest and that of other users in the identification and prevention of fraud and clarification of criminal offences.

Choice of payment methods

Before we show you the payment methods available for a purchase, Custombella will carry out a risk assessment. Your previously collected purchase data, payment details, creditworthiness data, data on your previous payment behaviour as well as your profile information (such as surname, first name, delivery and billing address, email address, date of birth) will be used to carry out the risk assessment. The assessment and evaluation will be carried out automatically using statistically justified estimates of the default risk in relation to the payment methods we offer. Within the framework of the risk assessment, Custombella also transmits your data to external credit agencies to receive general information from these on the evaluation of the payment-specific default risks (e.g. on whether your address is plausible and up-to-date) as well as, in individual cases, creditworthiness data, perhaps on open invoices and circumstances directly resulting in a risk of payment default (e.g. insolvency, deferral due to inability to pay). Which specific creditworthiness data is taken into account in the course of the risk assessment may vary from country to country.


You can find country-specific information on the credit agencies charged with carrying out the risk assessment and on the creditworthiness data used under “country-specific information”.

The default risk is assessed separately for each payment method in the form of an estimate. If the risk assessment yields a positive result, we can offer all the payment methods we generally offer. Otherwise, we will only offer you particular payment methods. Factors which may influence the availability of a payment method include:

  • The combination of name and address could not be found. This may result from typing errors, moves, marriage or a change of district.
  • You have given a delivery address, packing station or company address differing from the billing address.
  • There are still open claims against you.
  • There have been payment disruptions with particular payment methods in the past.

The risk assessment will not mean that you are not offered any payment method. If you are not in agreement with the payment methods offered, you can inform us of this in writing by letter or email at We will then check the decision again, taking your viewpoint into account.

Legal basis:

If you have given consent to the processing of your data as described above for the choice of payment methods, the legal basis is Article 6 (1) a GDPR (Consent). Otherwise, the legal basis is Article 6 (1) f GDPR, based on our legitimate interest in avoiding default risks.

Notice of withdrawal

You have the right to withdraw consent to the collection of creditworthiness data for selection of the payment method. You can find more information under “Which data protection rights do I have?”

Credit check

In addition to the risk assessment Custombella, processes your data before showing you the payment methods we make available for a purchase from us, in the course of an automated credit check. This check serves to prevent payment defaults and to ensure our security, as it allows us to recognise attempted fraud and other offences.

Along with data already in Custombella's possession, creditworthiness data from external credit agencies in the form of score values is also used. Score values are statistically justified estimates of the future risk of a person defaulting and are represented as a numerical value, such as a percentage. To this end, Custombella transmits on our behalf the personal data required for a credit check (generally your first and last name, your address and if necessary your date of birth) to the external agency. Address data may also be taken into account when calculating your score. The credit agency uses the data transmitted by us to correspondingly assess your creditworthiness on the basis of mathematical-statistical procedures.


You can find information on the credit agencies charged with carrying out credit checks in your country under “Country-specific information”. If your country is not listed here, we do not carry out credit checks in your country.

Depending on the result of the credit check, i.e. whether it is positive or negative, we will show you appropriate payment methods which you can use to continue and complete your purchase.

If you are not in agreement with this, you can inform us of this in writing or by email at We will then check the decision again, taking your viewpoint into account.

Legal basis:

The legal basis for the credit check described above is Article 6 (1) b GDPR, because it is necessary for the execution of necessary pre-contractual measures. This processing of your data otherwise occurs on the basis of Article 6 (1) f GDPR, based on our legitimate interest and that of other users in the avoidance of payment defaults, the identification and prevention of fraud and the clarification of criminal offences.

2.5 Advertising and market research, data analysis

We use your data, also within the framework of data analysis, for advertising and market research, in particular for the following purposes:

  • Classification into various target and user groups within the framework of market research (user segmentation).
  • Findings on various target groups and their respective usage habits and shopping interests.
  • The production of findings on demography, interests, our users’ shopping and usage habits as well as the marketing on these findings within the framework of advertising services provided to third parties.
  • The early identification of trends in the areas of fashion and online shopping.
  • The execution of advertising to existing customers.
  • The execution of direct marketing, e.g. in the form of newsletters.
  • The planning, execution and success monitoring of advertising corresponding to the interests of the target groups being addressed (personalised advertising).
  • Findings as to how our services are used (usage analysis).
  • The marketing of the above findings within the framework of advertising services for advertising customers.


Depending on the purpose, we use the data we have stored for data analysis. For example, we use summarised (aggregated), statistical, depersonalised (anonymised) profile information or data which can only be assigned to persons via further intermediate steps (pseudonymised profile information) as well as shopping and device and access data in order to understand and analyse purchasing processes using data analysis. This gives us anonymous or pseudonymised findings on our users’ general usage behaviour.

We process your data on the basis of balancing of interests to protect our legitimate interests or those of third parties (such as advertising partners or dealers which participate in Custombella’s partner programme). Custombella’s legitimate interest or that of third parties in data processing derives from the relevant purposes and is, unless otherwise indicated, of a competitive and economic nature.

Legal basis:

If data processing for the above purposes occurs with your consent, the legal basis is Article 6 (1) a GDPR (consent). This data processing data otherwise occurs on the basis of Article 6 (1) f GDPR, whereby the legitimate interests are for the above purposes.

2.6 Product and technology development

We use your data for product and technology development including the development and improvement of personalised services. In doing this we use aggregated, pseudonymised or anonymised data and machine learning algorithms, perhaps from our research, which facilitate estimates, prognoses and analysis in the interests of our users. In this way, for example, we can develop apps which can suggest products targeted to your interests and needs and recognise styles and assign products which correspond to your actual interests. Data is processed in relation to product and technology development particularly for the following purposes:

  • The development and improvement of personalised services and technologies for data analysis, advertising and personalised online shopping.
  • The development of technologies and concepts to improve IT security, prevent fraud and improve data protection e.g. by pseudonymisation, encryption and anonymisation technologies.
  • The development and testing of software solutions for the optimisation of necessary business and logistics processes.

Legal basis:

The legal basis for the processing of your data for product and technology development purposes is Article 6 (1) f GDPR, whereby our legitimate interests are in the above purposes.

2.7 Business management and business optimisation

We transmit and process your data where necessary for administrative and logistical processes and to optimise business processes within Custombella Group in order to design these in a more efficient and legally secure way and to fulfil our contractual and legal obligations (e.g. retention obligations under commercial and tax law). Many systems and technologies are shared within Custombella Group. This allows us to offer a more economical, secure, unified and personalised service. Therefore, various companies within Custombella Group have access to your data in so far as this is necessary for the fulfilment of the purposes named in this Data Protection Declaration.


  • If you contact Custombella customer service, your request is forwarded to Custombella payment service and processed there. Custombella payment service is responsible for paiement services in the Custombella Group. If this is necessary for the processing of your concern, a customer service employee from Custombella may access the data stored on you by other Custombella companies, for example your order data (e.g. in order to clarify your questions regarding a return).

Data processing for business management and business optimisation also includes, for example, the following purposes:

  • The execution and improvement of customer service.
  • The prevention and clarification of criminal offences.
  • Guaranteeing the security and operability of our IT systems.

Legal basis:

The legal basis for the processing of your data for business management and optimisation is Article 6 (1) f GDPR, whereby our legitimate interests are in the above purposes. Where we process your data on the basis of legal specifications, e.g. retention obligations and money laundering tests under tax law, the legal basis is Article 6 (1) c GDPR.

2.8 On the basis of your consent

If you have given us your consent for the processing of personal data, your consent is the primary basis of our data processing. Which of your data we process on the basis of your consent depends on the purpose of your consent. Typical purposes include:

  • Subscription to a newsletter.
  • Participation in surveys and market research studies.
  • The processing of particularly sensitive data, containing e.g. your political opinions, religious or ideological convictions or state of health.
  • The recording of telephone conversations which you have e.g. with our hotline.
  • The transmission of your data to third parties or to a country outside the European Union.
  • The execution of a credit check (if it is not necessary for contractual fulfilment or precontractual measures).

Notices of withdrawal

You can withdraw consent at any time with effect for the future, e.g. by e-mail or letter.

If the relevant service supports this function, you can adjust and withdraw consent to receive newsletters and other notifications in the preference centre. You can find the link to the preference centre in each newsletter. Each newsletter also contains a corresponding unsubscribe link.

You can find further instructions under “Which data protection rights do I have?”

2.9 Other purposes

If data protection law allows it, we can use your data for new purposes such as carrying out data analyses and developing our services and content without your consent. It is a prerequisite for this that these new purposes which the data is to be used for were not fixed or foreseeable when the relevant data was collected and the new purposes are compatible with the purposes for which the relevant data was originally collected. For example, new developments in the legal or technical sphere and new business models and services may lead to new processing purposes.

3. Personalised services

The development and provision of personalised functionalities and services for you is our top priority. We offer you an individual shopping experience and a range tailored to your individual interests, regardless of location, time and devices used. The processing of your data to personalise our service is therefore an integral part of Custombella’s service.


  • If you create a wish list in the Custombella app, you can view and edit this later on the Custombella website.
  • If you search for products on the Custombella website, we save your search terms. This allows us to show the results first which are probably particularly relevant to you when you search the Custombella website in future.
  • If you place a product in the basket, we can give you recommendations on the selection of a suitable clothing size on the basis of your previous orders and returns.
  • If you have subscribed to our newsletter, we can present you with products which fit your previous orders.

3.1 What are personalised services?

Personalised services allow us to offer you better, more practical and more secure services. To this end we use the data we have stored about you in order to determine your needs and interests. On this basis we can offer you more relevant content corresponding to your needs and interests. Of course, you still have access to all content. Personalisation allows you to see content which is more relevant to you more quickly, or content is specially presented to you (e.g. in the form of individual product recommendations).

3.2 Why do I need a customer account?

Most of our personalised services require you to set up a customer account so that we can save data we collect on you at a central location.

3.3 Which data is saved on my customer account?

Data which we collect about you is saved on your customer account, along with your customer number (customer ID). The customer number is a randomly generated sequence of numbers which does not contain any personal data. Your data is associated with your customer number, in order to link you to your customer account. The customer number also functions as a pseudonym.

3.4 Which data is used for personalisation?

Personalised content is generally selected on the basis of all data stored on your customer account.

If device and access data is used which is not saved on your customer account, these are only pseudonymised for the relevant personalisation (so e.g. in connection with your customer number, but not in connection with your named or other directly identifying profile data) for the duration of the usage.

Not used:

  • Creditworthiness data
  • Information for campaigns and surveys
  • Job applications
  • Notifications (e.g. from customer service)

3.5 Your options

You can view most of the data we have stored on your customer account at any time. If required you can also edit this data on your account and influence personalisation, perhaps by providing your preferences.

If personalisation is based on device and access data, you can prevent the collection of this data by deactivating the collection of this data by tracking tools. Please bear in mind, however, that you will receive less or no personalised content and services. Please bear in mind that the data used for personalised services are also needed for other purposes (including the provision of our services), in which case the collection of the data required will continue to be collected. However, the advertising presented to you will then not be personalised.

4. Info on websites and apps

We use your data to provide access to the Berlimoni's websites and apps. Along with the device and access data collected whenever you use these services, the type of data processed as well as the processing purposes depend especially on how you use the functions and services provided via our services. We also use the data collected when you use our services to find out how our online offering is used. We use this information and other information in the course of shopping personalisation to improve our services and for personalised advertising.

4.1 Providers

You can find the responsible service provider in the imprint of the relevant website or app.

4.2 Which data is collected?

We generally collect all the data which you directly share with us via our services.

Device and access data

Whenever you access our services and databases, we collect device and access data and record it in so-called server log files. The IP address it contains is anonymised shortly after the end of the relevant session, as soon as storage is no longer required to maintain the functionality of the relevant website.

If it is available and activated on your device, we also collect a device-specific ID number (e.g. a so-called “promo ID” if you are using an Android device or an “ad ID” if you are using an Apple device). This device ID is issued by the manufacturer of your operating system and can be read by websites and apps and used to present content on the basis of your usage habits. If you do not want this, you can deactivate it at any time in your device’s browser settings or system settings.


We set up password-protected personal access for users who register for a customer account or another service. If you do not log out again after logging in with your login details, most services automatically keep you logged in. Depending on the type of service, a cookie or similar technology is used for this. This function allows you to use part of our services without having to log in again every time. For security reasons, however, you will be asked to enter your password again if, for example, you want to change your profile information or submit an order. You can find more information under “Personalised services”

Social Plug-ins

Our services may contain social plug-ins (“plug-ins”) from various social networks. These plug-ins allow you, for example, to share content or recommend products. The plug-ins are deactivated as standard and therefore do not send any data. You can activate the plug-ins by clicking on the corresponding button (e.g. “activate social media”. The plug-ins can also be deactivated again with a click. If the plug-ins are activated, your web browser sets up a direct connection to the web servers of the relevant social network. The content of the plug-ins is then transferred by the social network directly to your web browser and integrated by the latter into our website. Integrating the plug-ins allows the social network to receive the information that you have called up the relevant page of our internet offering and can collect your device and access data. If you are logged into the social network, the latter may also assign the visit to your account with the relevant social network. If you interact with the plug-ins, for example by clicking the Facebook “like” button or making a comment, the corresponding information will be transmitted by your browser directly to the social network and stored there. The purpose and scope of the data collection, and the further processing and use of the data by the particular social networks and your rights and configuration options concerning this to protect your privacy, can be found in the privacy notices of the respective social networks and websites. You can find the links to these below. Even if you are not registered with the social networks, websites with active plug-ins may send data to the networks. An active plug-in will place a cookie with an ID each time you call up the website. Because your web browser sends this cookie without being asked every time you connect to a server, the social network could in principle create a profile of which websites the user belonging to the ID had called up. And it would also be quite possible to assign this ID to a person, for example if they later registered with the social network.

Social Logins

Our services may offer you the option of registering with us directly using your social network accounts. If you wish to use this function, you will first be forwarded to the relevant social network’s offering. There you will be asked to log in with your user name and password. Of course, we do not ourselves take note of your login details. If you are already logged in, this step will be skipped. The relevant social network then notifies you and asks you to confirm which data are transmitted to us (e.g. public profile, friends list, email address and current residence). We use the data transmitted to create your customer account, but will not, of course, save your friends list, for example. No further permanent connection between your customer account and your social network account will take place. We also receive social network data from the providers of the relevant social networks.

Shopping personalisation

Our services use the device and access data from the usage analysis, which are collected when you use our service, for shopping personalisation. Depending on the type of service, this may include common tracking technologies using tracking pixels and identification cookies or similar Ids (so-called tagging). In addition, our advertising partners may collect your device and access data in this way, in order to provide us with information on your interests and demographic data (such as age, gender, region) during your use of our services. This allows us to present you with advertising and/or particular offerings and services which correspond to your interests (for example product recommendations based on the fact that you have only viewed trainers in the last few days). Our goal when doing this is to make our offering as attractive to you as possible and to present you with advertising corresponding to your interest areas. Of course, you can continue to use all content and functions. This on-site optimisation does, however, allow us to first show you content and functions which are more relevant for you. On-site optimisation is carried out automatically by our systems, which recognise that users have repeatedly called up products and content from particular categories.

Find out more

You can find further information under “How does Custombella use my data for advertising?”

If you do not want on-site optimisation, you can deactivate this function at any time:

  • To do this, please deactivate the “data processing” function (in the Custombella app you will find this function on the info menu under the point “About us”).
  • In other services, please do this by deactivating web analysis or app analysis.

Info on website cookies

Our websites use cookies. Accepting cookies is not a prerequisite for using our websites. We would, however, like to point out that our websites can only function on a limited basis if you do not accept cookies. You can set your browser up in such a way that cookies are only saved if you agree to this.

What are cookies?

Cookies are small text files which are saved by your web browser and which save particular settings and data for exchange with our web server.

A distinction is generally made between two different types of cookies, so-called session cookies, which are deleted as soon as you close your browser, and temporary/permanent cookies which are stored for a longer period. Storing this data helps us to design our websites and services for you accordingly and makes them easier for you to use, for example by saving particular entries so that you do not have to repeat them constantly.

The cookies used by our website will only come from Custombella.