As of November 2026. This policy applies to shopware-free-theme.de.
1. Controller
TC-Innovations GmbH
Hanns-Martin-Schleyer-Straße 27
41564 Kaarst, Germany
Email: info@tc-innovations.de
We are not required to appoint a data protection officer. Please send any questions about data protection to the email address above.
2. Your rights
You have the right of access (Art. 15 GDPR), rectification (Art. 16 GDPR), erasure (Art. 17 GDPR), restriction of processing (Art. 18 GDPR) and data portability (Art. 20 GDPR). You may object to processing based on our legitimate interests on grounds relating to your particular situation (Art. 21 GDPR).
You may object at any time, without giving reasons, to the processing of your data for direct marketing, such as our newsletter (Art. 21(2) GDPR).
You can withdraw consent at any time with effect for the future (Art. 7(3) GDPR); for cookies and analytics, use the “Cookie settings” link in the footer of every page. Withdrawal does not affect the lawfulness of processing before the withdrawal.
You have the right to lodge a complaint with a data protection supervisory authority (Art. 77 GDPR), for example the authority responsible for us, the State Commissioner for Data Protection and Freedom of Information of North Rhine-Westphalia.
3. Hosting and server log files
This website is hosted by dogado GmbH, Antonio-Segni-Straße 11, 44263 Dortmund, Germany, on servers in Germany. We have a data processing agreement with dogado (Art. 28 GDPR).
When you open a page, the server automatically stores information your browser transmits: IP address, date and time, page requested, referrer URL, browser and operating system. This is necessary for secure and stable operation, for example to detect attacks (Art. 6(1)(f) GDPR). Log files are deleted after 14 days. Entries we need to investigate a specific security incident are kept until it has been resolved.
4. Cookies and consent
We set technically necessary cookies without consent (Section 25(2) No. 2 TDDDG, Art. 6(1)(f) GDPR). These are the cookies cookieconsent_essential, cookieconsent_analytics and cookieconsent_marketing. They only store your choice in the cookie banner and expire after 400 days. We run the banner ourselves on our server cookieconsent.tc-tools.de, also hosted by dogado; we do not use an external consent management provider. A session cookie (PHPSESSID), which the website uses to remember your language, expires when you close your browser.
Services that store or read further information on your device are only loaded after you consent (Section 25(1) TDDDG, Art. 6(1)(a) GDPR). Consent is voluntary; all functions of the website remain available without it. You can change or withdraw your choice at any time via “Cookie settings” in the footer.
5. Google Tag Manager and Google Analytics
With your consent, we use Google Analytics 4, integrated via Google Tag Manager. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Google Analytics creates pseudonymous statistics on how our website is used, such as which pages are viewed. We use these statistics to improve our website. Neither Tag Manager nor Google Analytics is loaded before you consent.
Google Analytics sets the cookies _ga and _ga_*, which expire after 400 days; the period restarts with each new visit. Google Analytics retains user and event data for two months and then deletes it in its monthly deletion run; new activity restarts the period for the user identifier; aggregated reports without personal reference remain.
The legal basis is your consent (Art. 6(1)(a) GDPR, Section 25(1) TDDDG). We have a data processing agreement with Google. Data may be transferred to Google LLC in the USA; Google LLC is certified under the EU-U.S. Data Privacy Framework (Art. 45 GDPR).
6. Email enquiries
This website has no contact form of its own. Enquiries, for example about branding removal, are handled via the contact form on tc-innovations.de; the privacy policy of tc-innovations.de (in German) applies there. If you email us, we process your details in order to answer your enquiry. We manage enquiries in the Freshdesk ticket system of Freshworks Inc., USA, which acts on our behalf (Art. 28 GDPR); transfers to the USA are based on the EU-U.S. Data Privacy Framework, under which Freshworks Inc. is certified (Art. 45 GDPR). We delete enquiries once they have been dealt with, unless a retention obligation under section 9 applies.
The legal basis is Art. 6(1)(b) GDPR where you are a party to a contract with us or are taking steps towards one. If you write as a representative of a company or without reference to a contract, processing is based on our legitimate interest in answering enquiries (Art. 6(1)(f) GDPR).
We manage enquiries in the Freshdesk ticket system of Freshworks Inc., USA, which acts on our behalf (Art. 28 GDPR). Transfers to the USA are based on the EU-U.S. Data Privacy Framework, under which Freshworks Inc. is certified (Art. 45 GDPR). We delete enquiries once they have been dealt with, unless a retention obligation under section 9 applies.
7. FreeTheme Essentials and newsletter with Klick-Tipp
We send you the FreeTheme Essentials by email. By requesting them you also subscribe to our newsletter, as described in the form. Without the newsletter, you can request the Essentials via a paid alternative delivery (EUR 59 plus VAT), linked in the form; this also requires your name and email address. Required details are your email address, whether you run Shopware self-hosted or in the cloud, and whether you are a shop owner or an agency; we use these to tailor the content. The language of the page is transmitted as well.
For sending we use Klick-Tipp, provided by KLICK-TIPP LIMITED, 15 Cambridge Court, 210 Shepherd’s Bush Road, London W6 7NJ, United Kingdom, as our processor. We only send you emails once you confirm your subscription via a confirmation link (double opt-in). We also store the time and IP address of subscription and confirmation. Klick-Tipp uses a tracking pixel and personalised links to record whether our emails are opened and which links are clicked so that we can evaluate our mailings. Where this stores or accesses information on your device, your consent also covers these operations (Section 25(1) TDDDG).
The legal basis for sending and evaluation is your consent (Art. 6(1)(a) GDPR). You can unsubscribe at any time via the link in every email; mailings then stop and we delete your data. We keep proof of your subscription separately until the end of the third calendar year after you unsubscribe, in order to defend against legal claims (Art. 6(1)(f) GDPR). Klick-Tipp automatically deletes unconfirmed subscriptions, usually after three and at the latest after seven days. The European Commission has issued an adequacy decision for the United Kingdom (Art. 45 GDPR).
8. YouTube videos
We embed videos in YouTube’s privacy-enhanced mode (youtube-nocookie.com). The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. A video is only loaded when you click it; no connection to YouTube is made before then. After the click, your browser transmits data such as your IP address to YouTube, and YouTube may store information on your device; data may be transferred to Google LLC in the USA. By clicking, you request the video yourself; storing information on your device is necessary for this (Section 25(2) No. 2 TDDDG), and processing is based on our legitimate interest in showing our videos (Art. 6(1)(f) GDPR). Transfers to the USA are based on Google LLC’s certification under the EU-U.S. Data Privacy Framework (Art. 45 GDPR). How long Google keeps this data is set out in Google’s Privacy Policy and retention policy.
9. Retention and encryption
Unless stated otherwise above, we delete personal data as soon as the purpose no longer applies. Documents we must retain for commercial and tax law reasons, such as business letters for six years and invoices for eight years, are deleted once these periods have expired (Art. 6(1)(c) GDPR in conjunction with Section 257 HGB and Section 147 AO). This website is encrypted throughout via TLS.