Privacy Policy

Last updated: October 1, 2026

1. Who We Are

This Privacy Policy explains how Volodymyr Kazonnikov, trading as Circumstance (“we”, “us”, or “our”), collects, uses, stores, and shares personal data when you visit our online store at circumstance.online, purchase our products, contact us, or otherwise interact with us.

Data Controller

Volodymyr Kazonnikov

Isländische Straße 9
10439 Berlin
Germany

Email:
volodymyrkazonnikov@gmail.com

We operate our business from Germany and sell clothing and fashion products through our Shopify online store.

For the purposes of the EU General Data Protection Regulation (GDPR), we act as the controller of personal data processed for the purposes described in this Policy, except where another party independently determines the purposes and means of processing.

2. Personal Data We Collect

The personal data we collect depends on how you interact with our store.

Information You Provide

When you place an order, contact us, or subscribe to marketing communications, we may collect:

• Name and surname.

• Billing and shipping address.

• Email address and telephone number, where provided.

• Products purchased, order history, and transaction references.

• Payment status and information needed to manage your order.

• Messages and information you provide through our contact form, email, or social media channels.

• Email marketing preferences and consent records, where applicable.

Please do not send payment card details or other sensitive personal information through our contact form or social media.

Payment Information

We offer payment methods including Shopify Payments, PayPal, and Klarna, subject to availability at checkout.

Payments are processed by the relevant payment service provider. We may receive payment confirmations, transaction references, payment status, and information needed to manage orders, refunds, disputes, and fraud prevention.

We do not intentionally store full payment card numbers or card security codes on our own systems.

Payment providers may process personal data under their own privacy policies and, where applicable, as independent controllers.

Automatically Collected Information

When you visit our store, Shopify and the technologies enabled on our website may collect technical information such as:

• IP address and approximate location derived from it.

• Browser, device, operating system, and language information.

• Pages and products viewed and interactions with the store.

• Session identifiers, cookie information, and consent preferences.

• Technical and security information related to website operation.

Non-essential cookies and tracking technologies are used only in accordance with applicable consent requirements.

3. How and Why We Use Personal Data

We process personal data for the following purposes:

Purpose	Legal basis
Processing orders, payments, and deliveries	GDPR Article 6(1)(b): performance of a contract
Responding to enquiries and providing customer support	Article 6(1)(b) where necessary for a contract or pre-contractual steps; otherwise, Article 6(1)(f), where applicable
Maintaining invoices, accounting records, and complying with tax obligations	Article 6(1)(c): legal obligation
Protecting the store, preventing fraud, and handling disputes	Article 6(1)(f): legitimate interests, where applicable
Sending promotional emails	Consent where required by applicable law
Using non-essential cookies, advertising pixels, and analytics technologies	Consent where required by applicable law
Handling legal claims and complying with lawful requests	Article 6(1)(c) or 6(1)(f), depending on the circumstances

Where we rely on legitimate interests, these may include protecting our business, maintaining website security, preventing misuse, and establishing or defending legal claims.

You may withdraw consent at any time where processing is based on consent. Withdrawal does not affect the lawfulness of processing before withdrawal.

4. Shopify and Website Hosting

Our online store is hosted on Shopify, which provides the e-commerce platform used to display products, manage orders, operate checkout, and support website functionality.

Shopify may process personal data to provide these services, maintain platform security, prevent fraud, and perform other functions described in its applicable privacy documentation.

Shopify's role may vary depending on the processing activity.

For more information, please review:

Shopify Privacy Policy: https://www.shopify.com/legal/privacy

Shopify Data Processing Addendum: https://www.shopify.com/legal/dpa

5. Payments

We offer Shopify Payments, PayPal, and Klarna as payment methods, subject to availability and the options displayed at checkout.

When you select a payment method, the relevant provider may process personal data necessary to complete the transaction, verify payment details, prevent fraud, manage refunds, and comply with legal obligations.

Please review the relevant provider's privacy information:

• Shopify: https://www.shopify.com/legal/privacy

• PayPal: https://www.paypal.com/privacy

• Klarna: https://www.klarna.com/international/privacy-policy/

The applicable provider and processing activities depend on the payment method you select.

6. Shipping and International Deliveries

We use DHL for shipping orders internationally.

To fulfil your order, we may share your name, shipping address, email address, telephone number where required, shipment details, and other information necessary for delivery with DHL and relevant logistics partners.

These parties may use the information to arrange delivery, provide tracking, contact recipients, manage delivery exceptions, and comply with applicable legal requirements.

For international shipments, personal data and shipment information may also be provided to customs authorities, customs intermediaries, and other parties involved in import or export procedures where necessary or legally required.

The information required depends on the destination country, shipment service, and applicable customs rules.

7. Email Marketing

If you subscribe to our marketing emails, we may use your email address to send information about new collections, product releases, restocks, and other brand-related updates.

We send promotional emails only where we have a valid legal basis under applicable data protection and electronic communications laws.

You can unsubscribe at any time using the unsubscribe link in a marketing email or by contacting us.

Unsubscribing from promotional emails does not prevent us from sending transactional messages necessary to process an order, arrange delivery, or respond to your enquiry.

We do not make consent to marketing a condition of purchasing our products.

We may retain limited information about your marketing preferences and withdrawal of consent to ensure that we respect your choices and comply with applicable law.

8. Contact Forms, Email, and Social Media

You can contact us through our website contact form, email, or social media channels, including Instagram where applicable.

We use the information you provide to respond to your enquiry, provide customer support, address order-related issues, and take any necessary pre-contractual steps.

If you contact us through a third-party social media platform, that platform may also process your personal data under its own privacy policy.

Please avoid sending sensitive personal information through social media or other unsecured communication channels.

9. Cookies and Similar Technologies

Our store may use cookies, pixels, and similar technologies to provide essential website functionality, remember preferences, protect security, and support advertising where enabled.

Essential technologies may be used where permitted by law. Non-essential technologies are activated only in accordance with applicable consent requirements.

Meta Pixel and Advertising

We plan to use the Meta Pixel to measure advertising performance, understand interactions with our store, and help measure conversions from advertisements on Meta platforms, such as Facebook and Instagram.

When implemented and enabled, the Meta Pixel may collect or receive information about your browser, device, IP address, pages viewed, product interactions, and events such as purchases, depending on the configuration.

Meta may associate this information with other information it holds and use it in accordance with its own privacy documentation and applicable terms.

We will configure the Pixel and any associated advertising tracking to respect applicable consent requirements. Where consent is required, non-essential tracking will not be activated before consent is obtained. You can change or withdraw your consent through the available cookie preference controls.

If we enable additional Meta data-sharing features, such as the Conversions API, those features may involve additional data processing and will be reflected in our privacy information as appropriate.

Meta Privacy Policy: https://www.facebook.com/privacy/policy/

Managing Cookie Preferences

You can manage non-essential cookie preferences through the cookie consent interface available on our store, where provided.

In Germany, the storage of information on or access to information from a user's terminal equipment is subject to Section 25 of the German Telecommunications-Digital Services Data Protection Act (TDDDG), subject to its applicable exceptions.

For visitors in the European Economic Area and the United Kingdom, applicable consent and data protection rules govern the use of non-essential tracking technologies.

The technologies actually used depend on our Shopify configuration and any installed apps or integrations.

10. Sharing Personal Data

We share personal data only where necessary for the purposes described in this Policy, where required by law, or where another lawful basis permits it.

Depending on the services enabled in our store, recipients may include:

• Shopify and website service providers.

• Shopify Payments, PayPal, Klarna, and relevant payment service providers.

• DHL and other logistics or customs service providers involved in delivery.

• Meta and relevant advertising service providers, where advertising tracking is enabled and lawfully permitted.

• Email marketing service providers, if used.

• Professional advisers, accountants, and legal advisers.

• Tax authorities, courts, regulators, and law enforcement authorities where legally required.

We do not claim to use every category of service listed above. The actual recipients depend on the services and integrations enabled in our store.

11. International Data Transfers

Because we sell internationally and use service providers that may operate in different countries, personal data may be transferred outside Germany or the European Economic Area.

Where Chapter V of the GDPR applies, international transfers are carried out using an applicable lawful transfer mechanism, which may include:

• An applicable European Commission adequacy decision.
• Standard Contractual Clauses approved by the European Commission, together with additional measures where required.

• Another transfer mechanism permitted by applicable data protection law.

Where required, you may contact us to request further information about the applicable safeguards.

International shipping may also require the disclosure of relevant shipment and recipient information to authorities and logistics partners in destination countries.

12. Data Retention

We retain personal data only for as long as necessary for the purposes described in this Policy, subject to applicable statutory retention requirements.

Retention periods depend on the type of information and the purpose for which it is processed.

Order, invoice, and accounting records may need to be retained for the periods prescribed by applicable German tax and commercial law.

Customer enquiries are retained for as long as reasonably necessary to respond to the enquiry and handle related matters.

Marketing information is retained until consent is withdrawn or the information is no longer required, subject to applicable legal obligations.

Technical and security information is retained according to operational, security, and legal requirements.

When personal data is no longer necessary and no legal obligation requires its retention, we will delete or anonymise it where appropriate.

13. Your Data Protection Rights

Depending on the applicable law and the circumstances, you may have the right to:

• Access your personal data.

• Request correction of inaccurate or incomplete data.

• Request deletion of your personal data where the legal conditions are met.

• Request restriction of processing in certain circumstances.

• Receive certain personal data in a structured, commonly used, machine-readable format where the legal conditions are met.

• Object to processing based on legitimate interests on grounds relating to your particular situation.

• Withdraw consent at any time where processing is based on consent.

• Object at any time to the processing of personal data for direct marketing.

• Lodge a complaint with a competent data protection supervisory authority.

These rights are subject to applicable legal conditions and exceptions. For example, we may be required to retain certain accounting or tax records even after receiving a deletion request.

To exercise your rights, contact us using the contact details in Section 1. We may request information reasonably necessary to verify your identity.

If you are in the European Economic Area, you may lodge a complaint with a competent supervisory authority, particularly in the EU Member State of your habitual residence, place of work, or the alleged infringement.

If you are in the United Kingdom, you may contact the Information Commissioner's Office (ICO), subject to the applicable rules.

14. United States Privacy Rights

Depending on your state of residence and whether the relevant law applies to our business, you may have additional privacy rights under applicable United States state privacy laws.

These rights may include requesting access to, correction of, or deletion of certain personal information, and opting out of certain processing for targeted advertising or the sale or sharing of personal information as defined by applicable law.

Where applicable, you may exercise your rights by contacting us using the details in Section 1.

If our use of advertising technologies, including Meta Pixel, constitutes a sale or sharing of personal information, or targeted advertising under a law applicable to our business, we will provide the required notices and opt-out mechanisms.

The availability and scope of these rights depend on the applicable law, your location, and whether the relevant legal thresholds and conditions are met.

15. Data Security

We use reasonable technical and organisational measures designed to protect personal data against unauthorised access, loss, alteration, disclosure, or destruction.

However, no method of electronic transmission or storage can be guaranteed to be completely secure.

16. Children's Privacy

Our store is intended for customers who are legally able to enter into purchases under applicable law.

We do not knowingly collect personal data from children in circumstances where such collection is prohibited by applicable law.

If you believe a child has provided personal data to us unlawfully, please contact us so that we can review the matter and take appropriate action.

17. Third-Party Websites

Our store may contain links to third-party websites and services, including payment providers, delivery tracking pages, and social media platforms.

Those services may process personal data under their own privacy policies. We do not control the privacy practices of independent third parties.

We recommend reviewing their privacy information when using their services.

18. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in our business, website functionality, service providers, or applicable legal requirements.

The latest version will be published on this page with its updated date. Where required by law, we will provide additional information or obtain consent before implementing changes that require it.

19. Contact Us

For questions about this Privacy Policy, our processing of personal data, or requests to exercise your privacy rights, please contact:

Volodymyr Kazonnikov

Isländische Straße 9
10439 Berlin
Germany

Email: volodymyrkazonnikov@gmail.com