data protection

privacy policy

1) Introduction and contact details of the person responsible

1.1 We are pleased that you are visiting our website and thank you for your interest. Below we will inform you about how we handle your personal data when you use our website. Personal data is all data that can be used to identify you personally.

1.2 The controller responsible for data processing on this website within the meaning of the General Data Protection Regulation (GDPR) is Orbique Ecommerce FZCO, Dubai Silicon Oasis IFZA Business Park, Building A1, 25315 Dubai, United Arab Emirates, email: info@myvlora.com. The controller responsible for the processing of personal data is the natural or legal person who alone or jointly with others decides on the purposes and means of processing personal data.

2) Data collection when visiting our website

2.1 If you use our website for information purposes only, i.e. if you do not register or otherwise provide us with information, we only collect data that your browser transmits to the website 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 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 anonymized form)

The processing is carried out in accordance with Art. 6 Paragraph 1 Letter f of GDPR on the basis of 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 subsequently check the server log files if there are concrete indications of illegal use.

2.2 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 SSL or TLS encryption. You can recognize an encrypted connection by the character string "https://" and the lock symbol in your browser line.

3) Hosting & Content Delivery Network

Shopify

To host our website and display the page content, we use the system of the following provider: Shopify International Limited, Victoria Buildings, 2nd Floor, 1-2 Haddington Road, Dublin 4, D04 XN32, Ireland (“Shopify”)

Data will also be transferred to: Shopify Inc., 150 Elgin St, Ottawa, ON K2P 1L4, Canada

All data collected on our website is processed on the provider's servers. We have concluded a data processing agreement with the provider that ensures the protection of our website visitors' data and prohibits unauthorized disclosure to third parties.

When data is transferred to Canada, an appropriate level of data protection is guaranteed by an adequacy decision of the European Commission.

4) Cookies

In order to make visiting our website more attractive and to enable the use of certain functions, we use cookies, i.e. small text files that are stored on your device. Some of these cookies are automatically deleted when you close the browser (so-called "session cookies"), while others remain on your device for longer and enable page settings to be saved (so-called "persistent cookies"). In the latter case, you can find out how long the cookies are stored in the overview of your web browser's cookie settings.

If personal data is also processed by individual cookies used by us, the processing is carried out in accordance with Art. 6 Para. 1 lit. b GDPR either for the execution of the contract, in accordance with Art. 6 Para. 1 lit. a GDPR in the case of consent granted 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.

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 in certain cases or in general.

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

5) Contact

When you contact us (e.g. via contact form or email), personal data will be processed exclusively for the purpose of processing and answering your request and only to the extent necessary for this purpose.

The legal basis for processing this data is our legitimate interest in answering your request in accordance with Art. 6 (1) (f) GDPR. If your contact is aimed at a contract, an additional legal basis for processing is Art. 6 (1) (b) GDPR. Your data will be deleted if it can be inferred from the circumstances that the matter in question has been conclusively clarified and provided that there are no statutory retention periods to the contrary.

6) Use of customer data for direct marketing

6.1 Registration for our email newsletter

If you sign up for our email newsletter, we will regularly send you information about our offers. The only mandatory information required to send the newsletter is your email address. Providing additional data is voluntary and will be used to address you personally. We use the so-called double opt-in procedure to send the newsletter, which ensures that you only receive the newsletter once you have expressly confirmed your consent to receive the newsletter by clicking on a verification link sent to the email address provided.

By activating the confirmation link, you give us your consent to use your personal data in accordance with Art. 6 Paragraph 1 Letter a of GDPR. We store your IP address entered by your Internet Service Provider (ISP) as well as the date and time of registration in order to be able to trace any possible misuse of your email address at a later date. The data we collect when you register for the newsletter is used strictly for the intended purpose.

You can unsubscribe from the newsletter at any time using the link provided in the newsletter or by sending a message to the person responsible named above. After unsubscribing, your email address will be immediately deleted from our newsletter mailing list unless you have expressly consented to further use of your data or we reserve the right to use the data in any other way that is permitted by law and about which we will inform you in this declaration.

6.2 Klaviyo

Our email newsletter is sent via this provider: Klaviyo, 225 Franklin St, Boston, MA 02110, USA

Based on our legitimate interest in effective and user-friendly newsletter marketing, we pass on the data you provided when registering for the newsletter to this provider in accordance with Art. 6 (1) (f) GDPR so that they can send the newsletter on our behalf.

Subject to your express consent in accordance with Art. 6 Paragraph 1 Letter a of GDPR, the provider also carries out a statistical evaluation of the success of newsletter campaigns using web beacons or tracking pixels in the emails sent, which can measure opening rates and specific interactions with the content of the newsletter. In doing so, end device information (e.g. time of access, IP address, browser type and operating system) is also collected and evaluated, but not merged with other data sets.

You can revoke your consent to newsletter tracking at any time with effect for the future.

We have concluded a data processing agreement with the provider that protects the data of our website visitors and prohibits the transfer to third parties.

For data transfers to the USA, the provider has joined the EU-US Data Privacy Framework, which ensures compliance with the European data protection level on the basis of an adequacy decision of the European Commission.

7) Data processing for order processing

7.1 To the extent necessary for the execution of the contract for delivery and payment purposes, the personal data collected by us will be passed on to the commissioned transport company and the commissioned credit institution in accordance with Art. 6 Paragraph 1 Letter b of GDPR.

If we owe you updates for goods with digital elements or for digital products on the basis of a corresponding contract, we will process the contact details you provided when ordering (name, address, email address) in order to inform you personally about upcoming updates within the legally stipulated period by suitable communication channels (e.g. by post or email) within the scope of our statutory information obligations in accordance with Art. 6 Paragraph 1 Letter c GDPR. Your contact details will be used strictly for the purpose of notifying you about updates owed by us and will only be processed by us for this purpose to the extent that this is necessary for the respective information.

To process your order, we also work with the following service provider(s), who support us in whole or in part in the implementation of concluded contracts. Certain personal data is transmitted to these service providers in accordance with the following information.

7.2 In order to fulfil our contractual obligations towards our customers, we work with external shipping partners. We pass on your name and delivery address and, if necessary for delivery, your telephone number, to a shipping partner selected by us exclusively for the purposes of delivering the goods in accordance with Art. 6 (1) (b) GDPR.

7.3 DSers

For order processing we use the following provider: Bowers Enterprises, LLC, 109 Cloister Drive, Peachtree City, GA 30269, USA

Name, address and, if applicable, other personal data will be passed on to the provider for the purpose of processing the online order in accordance with Art. 6 Paragraph 1 Letter b of GDPR. Your data will only be passed on if this is actually necessary for processing the order. The provider is also used for accounting. The provider processes incoming and outgoing invoices and, if applicable, our company's bank transactions in order to automatically record invoices, match them to transactions and use this to create financial accounting in a partially automated process.

If personal data is also processed, the processing is carried out in accordance with Art. 6 (1) (f) GDPR on the basis of our legitimate interest in the efficient organization and documentation of our business transactions.

For the transfer of data to the USA, the provider relies on standard contractual clauses of the European Commission, which are intended to ensure compliance with the European data protection level.

7.4 Use of payment service providers (payment services)

- Amazon Pay

One or more online payment methods from the following provider are available on this website: Amazon Payments Europe sca, 38 avenue JF Kennedy, L-1855 Luxembourg

If you select a payment method from the provider that requires you to pay in advance (such as credit card payment), the payment details you provided during the ordering process (including name, address, bank and payment card information, currency and transaction number) as well as information about the content of your order will be passed on to the provider in accordance with Art. 6 (1) (b) GDPR. In this case, your data will be passed on exclusively for the purpose of processing the payment with the provider and only to the extent that it is necessary for this purpose.
- Google Pay

If you choose the payment method “Google Pay” from Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland (“Google”), the payment will be processed via the “Google Pay” application on your mobile device running at least Android 4.4 (“KitKat”) and having an NFC function by charging a payment card stored with Google Pay or a payment system verified there (e.g. PayPal). To authorize a payment via Google Pay of more than €25, you must first unlock your mobile device using the verification measure set up in each case (e.g. facial recognition, password, fingerprint or pattern).

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 to the source website in the form of a unique transaction number, which is used to verify that the payment has been made. This transaction number does not contain any information about the actual payment data of your payment method stored with Google Pay, but is created and transmitted as a one-time numerical token. For all transactions via Google Pay, Google acts only as an intermediary to process the payment process. The transaction is carried out exclusively in the relationship between the user and the source website by charging the payment method stored with Google Pay.

If personal data is processed during the transmissions described, the processing is carried out exclusively for the purpose of payment processing in accordance with Art. 6 (1) (b) GDPR.

Google reserves the right to collect, store and evaluate certain transaction-specific information for each transaction made through Google Pay. This includes the date, time and amount of the transaction, the merchant location and description, a description of the goods or services purchased provided by the merchant, photos that you have attached to the transaction, the name and email address of the seller and buyer or 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 is carried out exclusively in accordance with Art. 6 (1) (f) GDPR on the basis of the legitimate interest in proper accounting, the verification of transaction data and the optimization and maintenance of the functionality of the Google Pay service.

Google also reserves the right to merge the processed transaction data with other information that is collected and stored by Google when using other Google services.

The Google Pay terms of use 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 at 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
- Paypal Checkout

This website uses PayPal Checkout, an online payment system from PayPal that consists of PayPal's own payment methods and local payment methods from third parties.

When paying via PayPal, credit card via PayPal, direct debit via PayPal or - if offered - "Pay later" via PayPal, we pass on your payment data to PayPal (Europe) Sarl et Cie, SCA, 22-24 Boulevard Royal, L-2449 Luxembourg (hereinafter "PayPal") as part of the payment processing. The data is passed on in accordance with Art. 6 Para. 1 lit. b GDPR and only to the extent that this is necessary for the 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 - "Pay later" via PayPal. For this purpose, your payment data may be passed on to credit agencies in accordance with Art. 6 Paragraph 1 Letter f of GDPR on the basis of PayPal's legitimate interest in determining your ability to pay. PayPal uses the result of the credit check in relation to the statistical probability of default for the purpose of deciding on the provision of the respective payment method. The credit report may contain probability values ​​(so-called score values). If 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, among other things, but not exclusively, address data. 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 the contractual payment processing.

If you select the PayPal payment method "purchase on account", your payment data will first be sent to PayPal to prepare the payment, after which PayPal will forward it to Ratepay GmbH, Franklinstraße 28-29, 10587 Berlin ("Ratepay") to process the payment. The legal basis is Art. 6 Para. 1 lit. b GDPR. In this case, RatePay carries out an identity and credit check in its own name to determine your ability to pay in accordance with the principle already mentioned above and passes your payment data on to credit agencies due to the legitimate interest in determining your ability to pay in accordance with Art. 6 Para. 1 lit. f GDPR. A list of the credit agencies that Ratepay can use can be found here: https://www.ratepay.com /legal-payment-creditagencies /

If you use the payment method of a local third-party provider, your payment data will initially be passed on to PayPal in accordance with Art. 6 (1) (b) GDPR to prepare the payment. Depending on your selection of an available local payment method, PayPal will then transmit your payment data to the relevant provider in accordance with Art. 6 (1) (b) GDPR to carry out the payment:

- Apple Pay (Apple Distribution International (Apple), Hollyhill Industrial Estate, Hollyhill, Cork, Ireland)
- Google Pay (Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland)
- Sofort (SOFORT GmbH, Theresienhöhe 12, 80339 Munich, Germany)
- iDeal (Currence Holding BV, Beethovenstraat 300 Amsterdam, Netherlands)
- giropay (Paydirekt GmbH, Stephanstr. 14-16, 60313 Frankfurt am Main
- bancontact (Bancontact Payconiq Company, Rue d'Arlon 82, 1040 Brussels, Belgium)
- blik (Polski Standard Płatności sp. z oo, ul. Czerniakowska 87A, 00-718 Warsaw, Poland)
- eps (PSA Payment Services Austria GmbH, Handelskai 92, Gate 2
1200 Vienna, Austria)
- MyBank (PRETA SAS, 40 Rue de Courcelles, F-75008 Paris, France)
- Przelewy24 (PayPro SA, Kanclerska 15A, 60-326 Poznań, Poland)

For further information on data protection, please refer to PayPal's privacy policy: https://www.paypal.com /de /webapps /mpp /ua /privacy-full
- IMMEDIATELY

One or more online payment methods from the following provider are available on this website: SOFORT GmbH, Theresienhöhe 12, 80339 Munich, Germany

If you select a payment method from the provider that requires you to pay in advance (such as credit card payment), the payment details you provided during the ordering process (including name, address, bank and payment card information, currency and transaction number) as well as information about the content of your order will be passed on to the provider in accordance with Art. 6 (1) (b) GDPR. In this case, your data will be passed on exclusively for the purpose of processing the payment with the provider and only to the extent that it is necessary for this purpose.
- Stripe

One or more online payment methods from the following provider are available on this website: Stripe Payments Europe Ltd., 1 Grand Canal Street Lower, Grand Canal Dock, Dublin, Ireland

If you select a payment method from the provider that requires you to pay in advance (such as credit card payment), the payment details you provided during the ordering process (including name, address, bank and payment card information, currency and transaction number) as well as information about the content of your order will be passed on to the provider in accordance with Art. 6 (1) (b) GDPR. In this case, your data will be passed on exclusively for the purpose of processing the payment with the provider and only to the extent that it is necessary for this purpose.

If you select a payment method where the provider makes an advance payment (e.g. purchase on account, installment plan or direct debit), you will also be asked to provide certain personal data (first and last name, street, house number, postcode, city, date of birth, email address, telephone number, if applicable, data on an alternative payment method) during the ordering process.

In order to protect our legitimate interest in determining the solvency of our customers, we will forward this data to the provider for the purpose of a credit check in accordance with Art. 6 Paragraph 1 Letter f of GDPR. The provider will check on the basis of the personal data you provide and other data (such as shopping cart, invoice amount, order history, payment experience) whether the payment option you have selected can be granted with regard to payment and/or default risks.

The credit report may contain probability values ​​(so-called score values). If 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, among other things, but not exclusively, address data.

You can object to this processing of your data at any time by sending a message to us or to the provider. However, the provider may still be entitled to process your personal data if this is necessary for the contractual payment processing.

8) Retargeting/remarketing and conversion tracking

Meta Pixel

Within our online offering we use the "Meta Pixel" service of the following provider: Meta Platforms Ireland Limited, 4 Grand Canal Quare, Dublin 2, Ireland ("Meta")

If a user clicks on an ad we have placed on Facebook and/or Instagram, a parameter is added to the URL of our linked page using "Meta Pixel". This URL parameter is then entered into the user's browser after redirection via a cookie that our linked page itself sets.

This enables Meta to determine the visitors to our online offering as a target group for the display of advertisements (so-called "ads"). Accordingly, we use the service to only display the Facebook and/or Instagram ads placed by us to users who have also shown an interest in our online offering or who have certain characteristics (e.g. interests in certain topics or products determined based on the websites visited) which we transmit to Meta (so-called "custom audiences").

On the other hand, the “meta pixel” can be used to track whether users were redirected to our website after clicking on an advertisement and which actions they performed there (so-called “conversion tracking”).

The data collected is anonymous to us and does not allow us to draw any conclusions about the identity of the user. However, the data is stored and processed by Meta so that a connection to the respective user profile is possible and Meta can use the data for its own advertising purposes.

All processing described above, in particular the setting of cookies for reading information on the device used, will only be carried out if you have given us your express consent in accordance with Art. 6 Paragraph 1 Letter a of GDPR. You can revoke your consent at any time with effect for the future by deactivating this service in the "Cookie Consent Tool" provided on the website.

We have concluded a data processing agreement with the provider, which ensures the protection of the data of our website visitors and prohibits unauthorized disclosure to third parties.

The information generated by Meta is usually transferred to a Meta server and stored there; in this context, it may also be transferred to Meta Platforms Inc. servers in the USA.

For data transfers to the USA, the provider has joined the EU-US Data Privacy Framework, which ensures compliance with the European data protection level on the basis of an adequacy decision of the European Commission.

9) Page functionalities

9.1 Facebook plugins

Our website uses plugins from the social network of the following provider: Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland

These plugins enable direct interactions with content on the social network.

In order to increase the protection of your data when you visit our website, the plugins are initially deactivated and integrated into the site using the so-called “2-click” or “Shariff” solution.

This integration ensures that when you access a page on our website that contains such plugins, no connection is established with the provider's servers.

Only when you activate the plug-ins and thereby give your consent to the data transfer in accordance with Art. 6 Paragraph 1 Letter a of GDPR will your browser establish a direct connection to the provider's servers. In this case, regardless of whether you log in to an existing user profile, a certain amount of information about the device you are using (including your IP address), your browser and your page history will be transmitted to the provider and may be further processed there.

If you are logged into an existing user profile on the provider's social network, information about interactions carried out via the plug-ins will also be published there and displayed to your contacts.
You can revoke your consent at any time by deactivating the activated plugin by clicking on it again. However, the revocation has no influence on the data that has already been transferred to the provider.

Data may also be transferred to: Meta Platforms Inc., USA

We have concluded a data processing agreement with the provider, which ensures the protection of the data of our website visitors and prohibits unauthorized disclosure to third parties.

For data transfers to the USA, the provider has joined the EU-US Data Privacy Framework, which ensures compliance with the European data protection level on the basis of an adequacy decision of the European Commission.

9.2 Instagram plugins

Our website uses plugins from the social network of the following provider: Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2 Ireland

These plugins enable direct interactions with content on the social network.

In order to increase the protection of your data when you visit our website, the plugins are initially deactivated and integrated into the site using the so-called “2-click” or “Shariff” solution.

This integration ensures that when you access a page on our website that contains such plugins, no connection is established with the provider's servers.

Only when you activate the plug-ins and thereby give your consent to the data transfer in accordance with Art. 6 Paragraph 1 Letter a of GDPR will your browser establish a direct connection to the provider's servers. In this case, regardless of whether you log in to an existing user profile, a certain amount of information about the device you are using (including your IP address), your browser and your page history will be transmitted to the provider and may be further processed there.

If you are logged into an existing user profile on the provider's social network, information about interactions carried out via the plug-ins will also be published there and displayed to your contacts.
You can revoke your consent at any time by deactivating the activated plugin by clicking on it again. However, the revocation has no influence on the data that has already been transferred to the provider.

Data may also be transferred: Meta Platforms Inc., USA

We have concluded a data processing agreement with the provider, which ensures the protection of the data of our website visitors and prohibits unauthorized disclosure to third parties.

For data transfers to the USA, the provider has joined the EU-US Data Privacy Framework, which ensures compliance with the European data protection level on the basis of an adequacy decision of the European Commission.

10) Tools and Others

- sevDesk

To handle accounting, we use the cloud-based accounting software service of the following provider: sevDesk GmbH, Hauptstraße 115, 77652 Offenburg, Germany

The provider processes incoming and outgoing invoices and, if applicable, our company's bank transactions in order to automatically record invoices, match them to transactions and use these to create financial accounting in a partially automated process.

If personal data is also processed, the processing is carried out in accordance with Art. 6 (1) (f) GDPR on the basis of our legitimate interest in the efficient organization and documentation of our business transactions.

11) Rights of the data subject

11.1 The applicable data protection law grants you the following data subject rights (rights to information and intervention) vis-à-vis the controller with regard to the processing of your personal data, whereby reference is made to the legal basis stated for the respective conditions for exercising them:

  • Right to information pursuant to Art. 15 GDPR;
  • Right to rectification pursuant to Art. 16 GDPR;
  • Right to erasure pursuant to Art. 17 GDPR;
  • Right to restriction of processing pursuant to Art. 18 GDPR;
  • Right to information pursuant to Art. 19 GDPR;
  • Right to data portability according to Art. 20 GDPR;
  • Right to revoke consent granted in accordance with Art. 7 Para. 3 GDPR;
  • Right to complain according to Art. 77 GDPR.

11.2 RIGHT OF OBJECTION

IF WE PROCESS YOUR PERSONAL DATA BASED ON OUR OVERRIDING LEGITIMATE INTEREST AS PART OF A BALANCE OF INTERESTS, YOU HAVE THE RIGHT TO OBJECT TO THIS PROCESSING AT ANY TIME FOR REASONS ARISING FROM YOUR PARTICULAR SITUATION, WITH EFFECT FOR THE FUTURE.

IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL STOP PROCESSING THE DATA IN QUESTION. HOWEVER, WE RESERVE THE RIGHT TO CONTINUE PROCESSING IF WE CAN PROVE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING WHICH OVERRIDE YOUR INTERESTS, FUNDAMENTAL RIGHTS AND FREEDOMS, OR IF THE PROCESSING SERVES TO ASSERT, EXERCISE OR DEFEND LEGAL CLAIMS.

IF WE PROCESS YOUR PERSONAL DATA FOR THE PURPOSE OF DIRECT MARKETING, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF PERSONAL DATA CONCERNING YOU FOR THE PURPOSE OF SUCH ADVERTISING. YOU CAN EXERCISE YOUR OBJECTION AS DESCRIBED ABOVE.

IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL STOP PROCESSING THE DATA CONCERNED FOR DIRECT MARKETING PURPOSES.

12) Duration of storage of personal data

The duration for which personal data is stored is determined based on the respective legal basis, the purpose of processing and – if applicable – also on the respective statutory retention period (e.g. retention periods under commercial and tax law).

When processing personal data on the basis of an explicit consent in accordance with Art. 6 (1) (a) GDPR, the data concerned will be stored until you revoke your consent.

If there are statutory retention periods for data that are processed within the framework of legal or quasi-legal obligations on the basis of Art. 6 (1) (b) GDPR, these data will be routinely deleted after expiry of the retention periods, provided that they are no longer required to fulfill or initiate a contract and/or we no longer have a legitimate interest in continuing to store them.

When processing personal data on the basis of Art. 6 (1) (f) GDPR, these data will be stored until you exercise your right of objection in accordance with Art. 21 (1) GDPR, unless we can demonstrate compelling legitimate grounds for the processing which outweigh your interests, rights and freedoms, 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 (1) (f) GDPR, these data will be stored until you exercise your right of objection in accordance with Art. 21 (2) GDPR.

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