Privacy
As of 29 Sep 2026
This page informs the staff who use the FRAUENSCHUH CRM app: which data about customers and about yourself are processed, for what purpose, for how long, who receives them and which rights apply. The CRM app is an internal tool; this is not the privacy policy of the web shop. Draft – the legal assessment is reviewed by our data protection advisers.
Controller
- Frauenschuh Bekleidungs GmbH, Kitzbühel
- Address: [BITTE EINSETZEN]
- Privacy contact (e-mail): [BITTE EINSETZEN]
- Data protection officer, if appointed: [BITTE EINSETZEN]
Which customer data
The CRM app shows and maintains the customer records that the FRAUENSCHUH Cockpit combines from the web shop (Shopify) and the store till system (Advarics). On top of that comes what staff record during a conversation:
- Master data: name, e-mail address, phone number, postal address, language, customer type; for trade customers company and VAT number; the assigned staff member.
- Birthday: day and month, the year optional – entered by hand only with the customer's consent; from the till system if it is stored there.
- Purchases: web shop orders and store receipts with item, colour, size, amount and returns; figures calculated from them and a classification (category, rank).
- Advice: notes, contact log, tasks and follow-ups, measurements and preferences (sizes, colours, materials, style, occasions, a free text on family), customer wishes (item, colour, size, store, contact details), service and alteration jobs, lists and tags.
- Consent per channel (e-mail, phone, post, WhatsApp, SMS) with a log: who, when, for what reason.
- A block note with reason if a customer must not be contacted any more.
Your data as a user
- Account: name, e-mail address, role, who created the account, last sign-in.
- Passkey: only the public key. Face, fingerprint or device PIN never leave your device.
- Sessions: start, last activity, expiry and the browser identifier of the device.
- Access log: who opened which customer record and when; log of exports and data access reports.
- Sign-in protection: number of failed attempts per device and any lock, without IP address.
- Your settings, for example data source, period, saved filters.
- Only if you enable push notifications on a device: the delivery address of your device’s push service with two keys, a rough device name (e.g. “iPhone”), since when, last delivery and the number of failures. Deleted when you remove the device, together with your account, or when the push service reports the address as expired.
- Only if the AI is switched on (currently off): a cost log per request with the customer numbers involved.
Purposes and legal bases
Proposal for review by our data protection advisers – not a final legal assessment.
| Purpose | Legal basis (proposal) |
|---|---|
| Customer wishes, reservations, service and alteration jobs, order queries | Contract and pre-contractual request, Art. 6(1)(b) GDPR |
| Personal advice and care, follow-ups, analysis of our own customer base, map | Legitimate interest, Art. 6(1)(f) GDPR |
| Marketing contact by e-mail, phone, post, WhatsApp or SMS; birthday reminder | Consent, Art. 6(1)(a) GDPR – for electronic marketing also § 174 TKG 2021 |
| Access, sign-in protection, access and export log | Legitimate interest in securing customer data, Art. 6(1)(f) and Art. 32 GDPR |
| Access, rectification and erasure on request, erasure record | Legal obligation, Art. 6(1)(c) GDPR |
Retention
What actually exists today – without promises the system does not keep:
- Customer records: until erasure or anonymisation on request. There is no automatic period for inactive customers yet; a proposal awaits a management decision.
- After erasure on request, the transactions remain without personal reference, plus an erasure record without names.
- Sign-in: a session ends after 12 hours without activity, at the latest after 7 days. Session entries are currently not deleted automatically.
- Failed attempts per device: deleted 30 days after the last attempt.
- Access log of customer records: 90 days; the Cockpit deletes older entries once a day.
- AI cost log: no period yet – the AI is switched off; a period will be set before it is switched on.
- Database backups: up to 31 days according to the setting at the database provider.
Recipients and service providers
| Service | Purpose, which data | Location |
|---|---|---|
| Fly.io (hosting the app) | The CRM app's server; processes all data the app shows. | Data centre Frankfurt; provider based in the USA |
| PlanetScale (database) | Stores all customer records and logs – the same database as the Cockpit. | AWS Frankfurt (eu-central-1); provider based in the USA |
| Shopify | Source of web shop customers and orders. Your device loads product images directly from Shopify (IP address, no customer data). | [BITTE EINSETZEN] |
| Advarics (till system) | Source of store customers, receipts, items and stock. Fetched by the Cockpit, not by the CRM app. | [BITTE EINSETZEN] |
| Microsoft 365 (Cockpit e-mail) | The Cockpit sends notices to the team, e.g. “item arrived” for a customer wish with the customer's name and contact details. No e-mail goes to customers. | [BITTE EINSETZEN] |
| Your device’s push service (Apple, Google or Mozilla) | Only if you enable push notifications: the Cockpit (and, for the test notification, the CRM app) hands an end-to-end encrypted message to your device’s push service. The service cannot see the content, only delivery address, time and size. Content: wish number, store, reason and the link to the wish — no customer name. | USA possible (Apple, Google, Mozilla) |
| Map services: OpenFreeMap and Mapterhorn (via Cloudflare), EOX | Your device loads base map, satellite image and elevation data: IP address, browser identifier, map section. No customer data. | EOX: Vienna (provider's statement); Cloudflare: also outside the EU possible |
| MET Norway (weather) | The server only requests coordinates of fixed grid points. Neither your IP address nor customer data. | Norway (EEA) |
| WhatsApp (Meta) | Only if the customer has explicitly allowed WhatsApp and you tap “WhatsApp” in a record: phone number and message text go to WhatsApp via the wa.me link and open the WhatsApp app on your device. Nothing is sent until you send it there. | USA possible |
| Anthropic (AI) – currently switched off | Only if management switches the AI on: question, basic details, figures, notes and purchases of the customers concerned; never phone number or e-mail address. | USA |
For providers based or processing outside the EU, the basis of the transfer (e.g. adequacy decision or standard contractual clauses) is to be recorded by our data protection advisers: [BITTE EINSETZEN]
Rights of data subjects
Customers – and you as a user – have the right to:
- Access (Art. 15 GDPR)
- Rectification (Art. 16)
- Erasure (Art. 17)
- Restriction of processing (Art. 18)
- Data portability (Art. 20)
- Objection (Art. 21), for marketing at any time
- Withdrawal of consent with effect for the future (Art. 7(3))
- Complaint to the Austrian Data Protection Authority (www.dsb.gv.at)
In-house: if a customer asks for access or erasure, pass it on to management. The reply is due within one month. Access reports (PDF or JSON) and erasure are handled in the app and logged.
Cookies and storage on the device
The CRM app only sets technically necessary cookies. There is no analytics, no tracking, no advertising cookies and no third-party cookies. That is why no cookie banner appears.
| Name | Purpose | Duration |
|---|---|---|
| crm_sitzung (cookie) | Keeps you signed in; contains only an identifier, no data. | up to 7 days, ends on sign-out |
| crm_pruefung (cookie) | One-time challenge during passkey sign-in. | 5 minutes |
| crm_geraet (cookie) | Random device identifier for protection against too many failed attempts. | 400 days |
| crm_quelle (cookie) | Former choice of data source; no longer set, only removed. | is deleted |
| fs-begruesst (session storage) | Remembers that the logo was already shown after sign-in. | until the tab is closed |
| fs-karte-mass (session storage) | Chosen size measure of the circles on the map. | until the tab is closed |
| Push subscription (browser) | Only after you tap “Enable on this device”: the browser keeps the registration with the push service so notifications arrive. No customer data; notifications are shown, not stored. | until you remove the device or turn notifications off |
| crm-huelle-… (app cache) | Icons, fonts and program files so the app starts quickly. No customer data. | until the next app version |
Customer data are not stored on the device: without a connection the app only shows “No connection”. An older store for interrupted forms (crm-warteschlange) is deleted by the app on the next start.