Privacy Policy

Date: 01.01.2026

Important note on language

This English version is provided for con­veni­ence only. The German version is legally au­thor­it­at­ive. In the event of in­con­sist­en­cies, am­bi­gu­ities or conflicts between the German version and any trans­la­tion, the German version shall prevail.

1. Data protection at a glance

General in­form­a­tion

The following in­form­a­tion provides an overview of what happens to your personal data when you visit this website or contact FRILISA.

Personal data means all data that can be used to personally identify you. This includes, in particular, your name, address, telephone number, e-mail address, ap­point­ment data, payment data, order data, meas­ure­ments, photos, videos, com­mu­nic­a­tion content, garment details, invoice data and technical usage data.

Detailed in­form­a­tion on data protection can be found in this Privacy Policy.

Data collection on this website

Data processing on this website is carried out by the website operator. The contact details can be found in the section “Controller” of this Privacy Policy.

Your data is collected, on the one hand, when you provide it to us, for example by e-mail, telephone, messenger, social media or in person at the atelier.

Other data is collected auto­mat­ic­ally by our IT systems when you visit the website. This primarily includes technical data, such as your internet browser, operating system, time of page access, IP address or server log data.

Part of the data is collected in order to ensure error-free, secure and stable provision of the website. Other data is processed in order to respond to enquiries, coordinate ap­point­ments, prepare orders, fulfil contracts, process payments, comply with legal ob­lig­a­tions or protect FRILISA’s legitimate interests.

FRILISA currently does not use analytics or tracking tools.

Your rights

Subject to statutory re­quire­ments, you have in particular the right of access, rec­ti­fic­a­tion, erasure, re­stric­tion of processing, data port­ab­il­ity, objection to certain processing operations, withdrawal of consent with effect for the future and the right to lodge a complaint with a data protection su­per­vis­ory authority.

You may contact us at any time regarding these rights and any other questions relating to data protection.

2. Controller

The controller re­spons­ible for data processing is:

FRILISA GmbH
Uh­land­straße 130
10717 Berlin
Germany

Rep­res­en­ted by: Viktor Fromm and Larissa Fromm
Phone: +49 30 2000 56 01
E-mail: info@frilisa.com

The controller is the natural or legal person who, alone or jointly with others, determines the purposes and means of the processing of personal data.

3. Data protection contact

For questions regarding data protection, the processing of personal data or the exercise of your rights, you may contact us:

FRILISA GmbH
Uh­land­straße 130
10717 Berlin
Germany
E-mail: info@frilisa.com
Phone: +49 30 2000 56 01

A data protection officer has not currently been appointed unless there is a statutory obligation to appoint one. If a data protection officer is appointed, their contact details will be added to this Privacy Policy.

4. General in­form­a­tion on data processing

We treat your personal data con­fid­en­tially and in accordance with statutory data protection provisions and this Privacy Policy.

We process personal data only insofar as this is necessary for the provision of our services, handling of enquiries, ap­point­ment co­ordin­a­tion, contract fulfilment, payment processing, com­mu­nic­a­tion, compliance with statutory ob­lig­a­tions, protection of legitimate interests or on the basis of consent.

Please note that data trans­mis­sion on the internet, for example when com­mu­nic­at­ing by e-mail or messenger, may have security gaps. Complete protection of data against access by third parties is not possible.

5. Legal bases of processing

We process personal data in particular on the following legal bases:

a) Art. 6(1)(b) GDPR, if processing is necessary for the per­form­ance of pre-con­trac­tu­al measures or for the fulfilment of a contract;
b) Art. 6(1)(c) GDPR, if processing is necessary for compliance with a legal obligation;
c) Art. 6(1)(f) GDPR, if processing is necessary for the purposes of legitimate interests pursued by FRILISA or third parties and no overriding interests of the data subject conflict;
d) Art. 6(1)(a) GDPR, if you have given us your consent;
e) Art. 9(2)(a) GDPR, insofar as special categories of personal data are ex­cep­tion­ally processed on the basis of explicit consent.

Where consent has been obtained, it may be withdrawn at any time with effect for the future.

6. Hosting

We host the content of our website with the following provider:

ALL-INKL.COM - Neue Medien Münnich
Owner: René Münnich
Hauptstraße 68
02742 Frieder­sdorf
Germany

Details can be found in All-Inkl’s privacy in­form­a­tion.

The use of All-Inkl is based on Art. 6(1)(f) GDPR. We have a legitimate interest in the most reliable, secure and stable present­a­tion of our website.

If ap­pro­pri­ate consent has been obtained, processing is carried out ex­clus­ively on the basis of Art. 6(1)(a) GDPR and Section 25(1) TDDDG, insofar as the consent includes the storage of cookies or access to in­form­a­tion on the user’s end device. Consent may be withdrawn at any time.

Data processing agreement

We have concluded a data processing agreement for the use of the above-mentioned service. This is a data protection contract required by law which ensures that All-Inkl processes personal data of our website visitors only on our in­struc­tions and in compliance with the GDPR.

7. Website, server log files and technical data

When you visit our website, technical data may be processed auto­mat­ic­ally. This may include in particular IP address, date and time of access, pages accessed, referrer URL, browser type, operating system, data volume trans­ferred and technical server logs.

Processing takes place for the provision of the website, system security, error analysis, prevention of misuse and technical op­tim­isa­tion.

The legal basis is Art. 6(1)(f) GDPR. Our legitimate interest lies in a secure, stable and functional website.

8. SSL or TLS encryption

For security reasons and to protect the trans­mis­sion of con­fid­en­tial content, this website uses SSL or TLS encryption.

You can recognise an encrypted connection by the fact that the address line of the browser changes from “http://” to “https://” and by the lock symbol in your browser line.

If SSL or TLS encryption is activated, the data you transmit to us generally cannot be read by third parties.

9. Cookies, consent tools, analytics and tracking

FRILISA currently does not use analytics or tracking tools.

Google Fonts are integrated locally. Therefore, no personal data is trans­mit­ted to Google solely through the use of Google Fonts.

Currently, no cookie or consent tool is active on the website. If FRILISA uses a cookie or consent management tool in the future, CCM19 is currently intended for this purpose.

CCM19 may be used to obtain, document and manage consent to the use of certain cookies, services or external content.

Non-essential cookies, analytics, marketing or tracking tech­no­lo­gies will only be used insofar as consent is required and has been obtained.

10. Contact form and e-mail com­mu­nic­a­tion

The contact form on the FRILISA website merely serves to prepare a message for the user’s e-mail program. The message is then sent via the user’s e-mail program.

No content is per­man­ently stored on the FRILISA website server via this form.

If you contact us by e-mail, we process the data you transmit in order to handle your enquiry, com­mu­nic­ate with you, carry out pre-con­trac­tu­al measures and, where applicable, process the contract.

This may include in particular name, e-mail address, telephone number, request, com­mu­nic­a­tion content, photos, files, ap­point­ment wishes, order in­form­a­tion and other voluntary in­form­a­tion.

Processing takes place on the basis of Art. 6(1)(b) GDPR if your enquiry is related to the fulfilment of a contract or is required for the per­form­ance of pre-con­trac­tu­al measures. In all other cases, processing takes place on the basis of our legitimate interest in the effective handling of enquiries submitted to us pursuant to Art. 6(1)(f) GDPR or on the basis of your consent pursuant to Art. 6(1)(a) GDPR, if such consent has been requested.

File uploads via the website are currently not offered. Customers may send photos, documents or other files only by other means, in particular by e-mail.

The data trans­mit­ted to us by you remain with us until you request deletion, withdraw your consent to storage or the purpose for storage no longer applies. Mandatory statutory provisions, in particular statutory retention periods, remain unaffected.

11. Enquiries, com­mu­nic­a­tion and customer contact

If you contact us by e-mail, telephone, social media, messenger, SMS, in person at the atelier or by other means, we process the data you provide in order to handle your enquiry and for further com­mu­nic­a­tion.

This may include in particular name, contact details, request, com­mu­nic­a­tion content, photos, files, ap­point­ment wishes, order in­form­a­tion and other voluntary in­form­a­tion.

Processing takes place for the im­ple­ment­a­tion of pre-con­trac­tu­al measures, contract fulfilment or on the basis of our legitimate interest in the efficient handling of enquiries.

12. Messenger, telephone and digital com­mu­nic­a­tion

FRILISA may com­mu­nic­ate with customers via messenger and digital com­mu­nic­a­tion channels, in particular via:

a) WhatsApp Business;
b) Instagram Direct Messages;
c) Facebook Messenger;
d) SMS;
e) e-mail;
f) telephone.

If you use these com­mu­nic­a­tion channels, we process the data you transmit to handle your enquiry, coordinate ap­point­ments, com­mu­nic­ate with customers, carry out pre-con­trac­tu­al measures and, where applicable, process the contract.

Depending on the com­mu­nic­a­tion channel, additional data may be processed by the respective provider. The privacy in­form­a­tion of the respective provider applies to such processing.

Order-relevant content from messenger com­mu­nic­a­tion may be trans­ferred to the customer file, project file or accounting documents insofar as this is necessary for order processing, doc­u­ment­a­tion, subsequent customer support, legal defence or compliance with statutory ob­lig­a­tions.

Messenger con­ver­sa­tions are reviewed regularly. If no order results from a com­mu­nic­a­tion and the content is no longer needed for customer com­mu­nic­a­tion, ap­point­ment co­ordin­a­tion, doc­u­ment­a­tion, legal defence or statutory retention ob­lig­a­tions, it will generally be deleted after 12 to 24 months.

13. Com­mu­nic­a­tion via WhatsApp Business

For com­mu­nic­a­tion with customers, pro­spect­ive customers and other third parties, we use, among other services, WhatsApp Business. The provider is WhatsApp Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland.

Com­mu­nic­a­tion is end-to-end encrypted, which prevents WhatsApp or other third parties from gaining access to the com­mu­nic­a­tion content. However, WhatsApp may have access to metadata generated during the com­mu­nic­a­tion process, such as sender, recipient and time of com­mu­nic­a­tion. We also point out that WhatsApp may share personal data with companies of the Meta group.

The use of WhatsApp is based on our legitimate interest in com­mu­nic­at­ing as quickly and ef­fect­ively as possible with customers, pro­spect­ive customers and other business and con­trac­tu­al partners pursuant to Art. 6(1)(f) GDPR.

If cor­res­pond­ing consent has been requested, data processing is carried out ex­clus­ively on the basis of consent. This consent may be withdrawn at any time with effect for the future.

The com­mu­nic­a­tion content exchanged between you and us via WhatsApp remains with us until you request deletion, withdraw your consent to storage or the purpose for data storage no longer applies. Mandatory statutory provisions, in particular retention periods, remain unaffected.

We use WhatsApp in the WhatsApp Business variant.

Where required, we have concluded a data processing agreement with the provider or base the processing on another suitable data protection basis.

14. Online contracts, vouchers, products and bookings

At present, no binding online contracts are concluded via the FRILISA website. Likewise, no products, vouchers, con­sulta­tions or ap­point­ments are currently sold, paid for or bindingly booked directly via the website.

FRILISA plans to offer online services such as vouchers, products, online payments, payment links or online bookings in the future.

As soon as such functions are activated, this Privacy Policy will be sup­ple­men­ted and updated ac­cord­ingly.

15. Ap­point­ment booking via eTermin, SumUp or comparable systems

At present, FRILISA does not offer binding online ap­point­ment booking via an external booking system.

In the future, FRILISA may use booking systems such as eTermin, SumUp or comparable providers. In this case, in particular name, e-mail address, telephone number, desired ap­point­ment, ap­point­ment type, voluntary in­form­a­tion about the request, payment or re­ser­va­tion in­form­a­tion and technical booking data may be processed.

A binding online ap­point­ment booking, online payment or purchase or booking process will only be offered once the respective function has been tech­nic­ally and legally set up. This Privacy Policy will then be sup­ple­men­ted ac­cord­ingly.

Insofar as service providers process personal data on our behalf, this shall be done on the basis of a data processing agreement, insofar as legally required.

16. Orders, made-to-measure garments, al­ter­a­tions and atelier services

If you commission us with a made-to-measure garment, alteration, repair, refinement, con­sulta­tion, fitting or other atelier service, we process the data required for this purpose.

This may include in particular:

a) name and contact details;
b) invoice and payment data;
c) order data and service de­scrip­tion;
d) meas­ure­ments, fit in­form­a­tion and fitting notes;
e) in­form­a­tion about shoes, underwear, ac­cessor­ies or styling, insofar as relevant for the fit;
f) photos, sketches, designs, moodboards or reference images;
g) in­form­a­tion about materials, fabrics, garments and alteration requests;
h) com­mu­nic­a­tion history.

We process this data for con­sulta­tion, order processing, production, alteration, quality assurance, doc­u­ment­a­tion, invoicing and customer support.

Meas­ure­ments, fit in­form­a­tion and fitting notes may contain body-related in­form­a­tion. We process these only insofar as they are necessary for the requested service or you vol­un­tar­ily provide them to us.

17. Storage of customer data, meas­ure­ments, photos and project data

Customer photos, meas­ure­ments, fit data, fitting notes and project data may be stored on an encrypted server and/or in printed form.

The storage serves to process ongoing orders, answer later enquiries, prepare follow-up orders, document fit and project histories and protect legitimate interests of FRILISA as well as of the customer.

These data are generally stored as long as they are necessary for the stated purposes or until the customer requests deletion, unless statutory retention ob­lig­a­tions, legitimate interests or legal claims conflict.

Project photos may remain stored in the archive as long as follow-up orders are expected, further customer support is useful or the customer does not request deletion.

Marketing materials used on the basis of consent may be used and stored until the consent is withdrawn. After withdrawal, no new pub­lic­a­tion will take place on the basis of the withdrawn consent. Already published content will be removed or adapted to a reasonable extent.

Non-accepted offers and related business cor­res­pond­ence may remain stored in the accounting or ad­min­is­tra­tion system insofar as this is necessary for doc­u­ment­a­tion, trace­ab­il­ity, legal defence, internal or­gan­isa­tion or due to statutory retention ob­lig­a­tions.

18. Photos, videos, references and social media

Photos, videos or other personal content in which customers are re­cog­nis­able or from which con­clu­sions can be drawn about a specific person are used by us for reference, portfolio, social media, website, internet, print, press, ad­vert­ising or marketing purposes only with cor­res­pond­ing consent or on another legal basis.

Consent granted may be withdrawn at any time with effect for the future. The lawfulness of processing carried out up to the withdrawal remains unaffected.

Anonymised detail shots of seams, embroidery, materials, appliqués, artisanal processes, fabrics, cut details or non-personal workshop and product details may be used by us for portfolio, doc­u­ment­a­tion, present­a­tion or marketing purposes, provided that no legitimate interests conflict.

19. AI-assisted media editing and digital creative tools

FRILISA may use digital creative and AI-assisted tools, in particular:

a) Adobe / Photoshop;
b) Canva;
c) Suno;
d) Google Gemini.

These tools may be used in particular for text de­vel­op­ment, image editing, retouching, visu­al­isa­tion, design support, design pre­par­a­tion, music ideas, video ideas, marketing pre­par­a­tion or internal or­gan­isa­tion.

Personal customer photos are generally used in such tools only if this is necessary for the respective purpose, a suitable legal basis exists and re­cog­nis­able faces have previously been made un­re­cog­nis­able or separate consent has been obtained.

Where possible, FRILISA uses anonymised, pseud­onymised or non-personal content.

If re­cog­nis­able persons, voices, names, personal char­ac­ter­ist­ics or other iden­ti­fi­able content are affected, we use these for AI-assisted editing for marketing, reference or social media purposes only with cor­res­pond­ing consent or on another legal basis.

If AI-assisted service providers are used, personal data may be trans­mit­ted to them. We ensure that only such data is trans­mit­ted as is necessary for the respective purpose.

20. Payment methods and payment service providers

FRILISA offers in particular card payment, bank transfer, instant bank transfer, online payment or payment link.

Cash payment is not offered as a regular payment method, but may be accepted in ex­cep­tion­al cases by prior agreement.

For card payments, online payments or payment links, FRILISA may use payment service providers such as SumUp or comparable providers. In this context, in particular name, payment amount, payment date, payment method, trans­ac­tion data, invoice data and order reference may be processed.

Processing takes place for the execution of payments, contract processing, accounting, fulfilment of tax and commercial law ob­lig­a­tions and doc­u­ment­a­tion of payment trans­ac­tions.

The privacy in­form­a­tion of the respective payment service provider may ad­di­tion­ally apply to payment processing.

21. Invoicing, accounting and statutory retention

We process personal data for the pre­par­a­tion of offers, order con­firm­a­tions, invoices, credit notes, payment overviews and accounting records.

This may include in particular name, address, contact details, service data, payment data, tax data and invoice data.

Processing takes place for contract fulfilment and compliance with statutory retention, tax and accounting ob­lig­a­tions.

Business and tax-relevant documents are stored in accordance with statutory retention periods.

22. Newsletter

FRILISA currently does not offer a newsletter via separate newsletter software.

If FRILISA offers a newsletter in the future, the necessary in­form­a­tion, in particular on the provider used, the re­gis­tra­tion procedure, consent, un­sub­scribe options and the processing of personal data, will be included in this Privacy Policy.

23. Social media presences

FRILISA currently uses in particular the following social media presences:

a) Instagram;
b) Facebook;
c) LinkedIn.

If you visit our social media profiles, com­mu­nic­ate with us there, comment on posts, send messages or share content, personal data may be processed by us and by the respective platform provider.

We process data from social media com­mu­nic­a­tion for handling enquiries, com­mu­nic­a­tion, external present­a­tion, customer support and marketing.

The respective platform providers’ own privacy in­form­a­tion applies to data processing by those providers. We have only limited influence on the scope and purpose of data processing by the platform providers.

24. Recipients of personal data

Personal data may, where necessary, be trans­mit­ted to the following recipients or categories of recipients:

a) IT and hosting service providers, in particular All-Inkl;
b) providers of ap­point­ment booking and management systems, in particular eTermin, SumUp or comparable providers, if used in the future;
c) payment service providers, banks and card payment providers;
d) tax advisers, accounting and auditors;
e) legal advisers, insurers or debt collection service providers, where necessary;
f) shipping service providers, where shipping has been agreed;
g) providers of digital creative, image, video, music, AI or design tools, insofar as necessary for the respective purpose;
h) providers of com­mu­nic­a­tion services, messengers and social media platforms, insofar as you use these com­mu­nic­a­tion channels;
i) au­thor­it­ies or public bodies, where there is a statutory obligation.

Data is disclosed only insofar as this is legally per­miss­ible and necessary for the respective purpose.

25. Third-country transfers

Insofar as personal data is trans­mit­ted to providers outside the European Union or the European Economic Area, this shall only take place if a suitable legal basis exists.

This may include in particular an adequacy decision of the European Commission, the conclusion of EU Standard Con­trac­tu­al Clauses, explicit consent or another legally per­miss­ible basis.

When using social media platforms, in­ter­na­tion­al payment service providers, AI, design, image, video, music, messenger or cloud services, transfer to third countries cannot be excluded.

26. Storage period

We store personal data only for as long as this is necessary for the respective purposes or statutory retention ob­lig­a­tions exist.

Enquiries and com­mu­nic­a­tion data are deleted when they are no longer required for handling and no statutory retention ob­lig­a­tions, legitimate interests or legal claims conflict.

Order, invoice and accounting data are stored in accordance with statutory retention ob­lig­a­tions.

Data processed on the basis of consent is stored until withdrawal of consent or until the purpose ceases to apply, unless statutory retention ob­lig­a­tions conflict.

Photos, videos, reference or marketing content used on the basis of consent may be used until consent is withdrawn, unless otherwise agreed within the scope of the consent.

Customer photos, meas­ure­ments, fit data, fitting notes and project data may be stored as long as they are necessary for ongoing or later orders, enquiries, pre­par­a­tion, doc­u­ment­a­tion, legal defence or legitimate interests, or until the customer requests deletion, unless statutory retention ob­lig­a­tions, legitimate interests or legal claims conflict.

Messenger con­ver­sa­tions without an order are generally reviewed and deleted after 12 to 24 months, insofar as they are no longer needed.

27. Data security

We take technical and or­gan­isa­tion­al measures to protect personal data against loss, misuse, un­au­thor­ised access, alteration or disclosure.

These include in particular access re­stric­tions, secure com­mu­nic­a­tion channels, careful selection of service providers, ap­pro­pri­ate storage of documents and or­gan­isa­tion­al protective measures in the atelier operation.

Customer photos, meas­ure­ments, fit data, fitting notes and project data may be stored on an encrypted server and/or in printed form.

28. Your rights

Subject to statutory provisions, you have the following rights:

a) right of access to the personal data processed by us;
b) right to rec­ti­fic­a­tion of inaccurate data;
c) right to erasure of personal data;
d) right to re­stric­tion of processing;
e) right to data port­ab­il­ity;
f) right to object to certain processing;
g) right to withdraw consent granted with effect for the future;
h) right to lodge a complaint with a data protection su­per­vis­ory authority.

To exercise your rights, you may contact us at any time:

FRILISA GmbH
Uh­land­straße 130
10717 Berlin
Germany
E-mail: info@frilisa.com

29. Right to object to data processing in special cases and to direct ad­vert­ising

If data is processed on the basis of Art. 6(1)(e) or (f) GDPR, you have the right to object at any time, on grounds relating to your particular situation, to the processing of your personal data. This also applies to profiling based on these provisions.

If you object, we will no longer process the personal data concerned unless we can demon­strate compelling legitimate grounds for the processing that override your interests, rights and freedoms, or the processing serves the es­tab­lish­ment, exercise or defence of legal claims.

If your personal data is processed for direct ad­vert­ising purposes, you have the right to object at any time to the processing of personal data concerning you for the purpose of such ad­vert­ising. This also applies to profiling insofar as it is related to such direct ad­vert­ising.

If you object, your personal data will sub­sequently no longer be used for direct ad­vert­ising purposes.

30. Withdrawal of consent

If processing is based on your consent, you may withdraw this consent at any time with effect for the future.

The lawfulness of processing carried out before the withdrawal remains unaffected.

31. Right to data port­ab­il­ity

You have the right to have data that we process auto­mat­ic­ally on the basis of your consent or in fulfilment of a contract handed over to you or to a third party in a common, machine-readable format.

If you request direct transfer of the data to another controller, this will only be done if tech­nic­ally feasible.

32. Access, rec­ti­fic­a­tion and erasure

Within the scope of statutory provisions, you have the right at any time to obtain in­form­a­tion about your stored personal data, its origin, recipients and the purpose of data processing.

You also have the right to have this data rectified or erased, provided that the statutory re­quire­ments are met.

33. Right to re­stric­tion of processing

You have the right to request re­stric­tion of the processing of your personal data.

The right to re­stric­tion of processing exists in particular if you dispute the accuracy of your personal data stored by us, if the processing is unlawful, if we no longer need the data but you need it for the es­tab­lish­ment, exercise or defence of legal claims, or if you have objected to processing and it has not yet been determined whose interests prevail.

34. Right to lodge a complaint with the su­per­vis­ory authority

You have the right to lodge a complaint with a data protection su­per­vis­ory authority if you believe that the processing of your personal data infringes data protection law.

The su­per­vis­ory authority generally re­spons­ible for FRILISA is:

Berliner Beau­ftragte für Datens­chutz und In­form­a­tionsfreiheit
Alt-Moabit 59-61
10555 Berlin
Germany
Phone: +49 30 13889-0
E-mail: mailbox@datens­chutz-berlin.de

35. Objection to un­so­li­cited ad­vert­ising e-mails

We object to the use of contact details published as part of the legal notice obligation for the purpose of sending ad­vert­ising and in­form­a­tion materials that have not been expressly requested.

FRILISA expressly reserves the right to take legal action in the event of un­so­li­cited ad­vert­ising in­form­a­tion being sent, for example by spam e-mails.

36. Updates to this Privacy Policy

We may amend this Privacy Policy if our data processing, services used, legal re­quire­ments or technical processes change.

The current version made available on our website or on request shall apply.