Privacy Policy
1) Introduction and contact details of the controller
1.1 We are pleased that you are visiting our website and thank you for your interest. Below we inform you about how we handle your personal data when using our website. Personal data is any data by which you could be personally identified.
1.2 The controller responsible for data processing on this website within the meaning of the General Data Protection Regulation (GDPR) is Magdalena Czuban, Rudolf-Seiffert-Str. 84a, 10369 Berlin, Germany, tel.: +49 (0) 15510793023, e-mail: info@balance-journey.com. The controller for the processing of personal data is the natural or legal person who alone or jointly with others determines the purposes and means of the processing of personal data.
2) Data collection when visiting our website
2.1 In the case of merely informational use of our website, i.e. if you do not register or otherwise transmit information to us, we only collect the data that your browser transmits to our server (so-called "server log files"). When you access our website, we collect the following data, which is technically necessary for us to display the website to you:
- The website you visited
- Date and time at the moment of access
- Amount of data sent in bytes
- Source/reference from which you arrived at the page
- Browser used
- Operating system used
- IP address used (if applicable: in anonymised form)
Processing takes place in accordance with Art. 6 (1) (f) GDPR on the basis of our legitimate interest in improving the stability and functionality of our website. The data is not passed on or otherwise used. We nevertheless reserve the right to review the server log files retrospectively if there are concrete indications of unlawful 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 controller), this website uses SSL or TLS encryption. You can recognise an encrypted connection by the string "https://" and the padlock symbol in your browser bar.
3) Hosting & Content Delivery Network
For the hosting of our website and the presentation of the page content, we use a provider who performs its services itself or through selected sub-contractors exclusively on servers located within the European Union.
All data collected on our website is processed on these servers.
We have concluded a data processing agreement with the provider that ensures the protection of the data of our website visitors and prohibits unauthorised disclosure to third parties.
4) Cookies
In order to make visiting our website attractive and to enable the use of certain functions, we use cookies, i.e. small text files that are stored on your end device. Some of these cookies are automatically deleted after the browser session ends (so-called "session cookies"), while others remain on your end device for a longer period and enable page settings to be saved (so-called "persistent cookies"). In the latter case, you can find information on the storage period in the overview of the cookie settings of your web browser.
Insofar as personal data is also processed by individual cookies we use, processing takes place in accordance with Art. 6 (1) (b) GDPR either for the performance of the contract, in accordance with Art. 6 (1) (a) GDPR in the case of consent given, or in accordance with Art. 6 (1) (f) GDPR to safeguard our legitimate interests in the best possible functionality of the website as well as a customer-friendly and effective design of the visit to the site.
You can set your browser so that you are informed about the placement of cookies and decide individually whether to accept them, or exclude the acceptance of cookies for certain cases or generally.
Please note that if you do not accept cookies, the functionality of our website may be limited.
5) Contacting us
When you contact us (e.g. by contact form or e-mail), personal data is processed – solely for the purpose of handling and responding to your inquiry, and only to the extent necessary for that purpose.
The legal basis for the processing of this data is our legitimate interest in responding to your inquiry in accordance with Art. 6 (1) (f) GDPR. If your contact is aimed at concluding a contract, the additional legal basis for the processing is Art. 6 (1) (b) GDPR. Your data will be deleted once it can be inferred from the circumstances that the matter concerned has been conclusively clarified, provided that no statutory retention obligations stand in the way.
6) Comment function
In connection with the comment function on this website, in addition to your comment, information on the time the comment was created and the commenter name you chose will be stored and published on this website. In addition, your IP address is logged and stored. This storage of the IP address takes place for security reasons and in case the data subject violates the rights of third parties or posts unlawful content through a submitted comment. We need your e-mail address in order to contact you should a third party object to your published content as unlawful.
The legal bases for storing your data are Art. 6 (1) (b) and (f) GDPR. We reserve the right to delete comments if they are objected to by third parties as unlawful.
7) Use of customer data for direct marketing
7.1 Sign-up to our e-mail newsletter
If you sign up for our e-mail newsletter, we will regularly send you information about our offers. The only mandatory information required to send the newsletter is your e-mail address. The provision of further data is voluntary and is used to be able to address you personally. For the dispatch of the newsletter, we use the so-called double opt-in procedure, which ensures that you only receive the newsletter once you have expressly confirmed your consent to receiving it by clicking on a verification link sent to the e-mail address provided.
By activating the confirmation link, you give us your consent to the use of your personal data in accordance with Art. 6 (1) (a) GDPR. We store the IP address assigned 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 e-mail address at a later date. The data collected by us when signing up for the newsletter is used strictly for this purpose.
You can unsubscribe from the newsletter at any time via the link provided in the newsletter or by sending a corresponding message to the controller named at the beginning. After unsubscribing, your e-mail address will be deleted immediately from our newsletter distribution list, unless you have expressly consented to further use of your data or we reserve the right to further data use that is legally permitted and about which we inform you in this policy.
7.2 Shopping cart reminders by e-mail
If you abandon your purchase with us before completing the order, you have the option of being reminded once by e-mail of the contents of your virtual shopping cart.
The only mandatory information required to send this reminder is your e-mail address. The provision of further data is voluntary and may be used to be able to address you personally. For sending this e-mail, we use the so-called double opt-in procedure, which ensures that you only receive a notification once you have expressly confirmed your consent by clicking on a verification link sent to the e-mail address provided.
By activating the confirmation link, you give us your consent to the use of your personal data in accordance with Art. 6 (1) (a) GDPR for sending a shopping cart reminder. We store the IP address assigned 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 e-mail address at a later date. The data collected by us when signing up for our e-mail notification service is used strictly for this purpose.
You can unsubscribe from the shopping cart reminders at any time by sending a corresponding message to the controller named at the beginning. After unsubscribing, your e-mail address will be deleted immediately from the distribution list set up for this purpose, unless you have expressly consented to further use of your data or we reserve the right to further data use that is legally permitted and about which we inform you in this policy.
8) Data processing for order fulfilment
8.1 Insofar as necessary for the performance of the contract for delivery and payment purposes, the personal data collected by us is passed on in accordance with Art. 6 (1) (b) GDPR to the transport company and the credit institution commissioned.
Insofar as, on the basis of a corresponding contract, we owe you updates for goods with digital elements or for digital products, we process the contact data you provided when placing your order in order to inform you personally within the scope of our statutory information obligations in accordance with Art. 6 (1) (c) GDPR. Your contact data is used strictly for the purpose of communications about updates owed by us and is processed by us for this purpose only to the extent necessary for the relevant information.
To process your order, we also work with the service provider(s) listed below, who support us in whole or in part in fulfilling concluded contracts. In accordance with the following information, certain personal data is transmitted to these service providers.
8.2 Use of payment service providers
- Amazon Pay
One or more online payment methods from the following provider are available on this website: Amazon Payments Europe s.c.a., 38 avenue J.F. Kennedy, L-1855 Luxembourg
If you select a payment method from the provider in which you pay in advance (such as credit card payment), your payment data 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 it in accordance with Art. 6 (1) (b) GDPR. In this case, your data is passed on exclusively for the purpose of payment processing with the provider and only to the extent necessary for this purpose.
- Apple Pay
If you choose the "Apple Pay" payment method from Apple Distribution International (Apple), Hollyhill Industrial Estate, Hollyhill, Cork, Ireland, payment processing takes place via the "Apple Pay" function of your end device running iOS, watchOS or macOS by charging a payment card stored in "Apple Pay". Apple Pay uses security features that are integrated into the hardware and software of your device to protect your transactions. To authorise a payment, you must therefore enter a code you have previously set as well as verification via the "Face ID" or "Touch ID" function of your end device.
For the purpose of payment processing, the information you provided during the ordering process, together with information about your order, is transmitted to Apple in encrypted form. Apple then re-encrypts this data with a developer-specific key before the data is transmitted to the payment service provider of the payment card stored in Apple Pay in order to carry out the payment. The encryption ensures that only the website through which the purchase was made can access the payment data. Once the payment has been made, Apple sends your device account number as well as a transaction-specific, dynamic security code to the originating website to confirm the success of the payment.
Insofar as personal data is processed in the course of the transmissions described, this processing takes place exclusively for the purpose of payment processing in accordance with Art. 6 (1) (b) GDPR.
Apple retains anonymised transaction data, including the approximate purchase amount, the approximate date and time, and whether the transaction was successfully completed. Anonymisation completely rules out any connection to a person. Apple uses the anonymised data to improve "Apple Pay" and other Apple products and services.
If you use Apple Pay on the iPhone or Apple Watch to complete a purchase made via Safari on a Mac, the Mac and the authorising device communicate via an encrypted channel on Apple's servers. Apple does not process or store any of this information in a format that can identify you personally. You can deactivate the ability to use Apple Pay on your Mac in your iPhone settings. Go to "Wallet & Apple Pay" and deactivate "Allow Payments on Mac".
Further information on data protection with Apple Pay can be found at the following internet address: https://support.apple.com/de-de/HT203027
- Google Pay
If you choose the "Google Pay" payment method from Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland ("Google"), payment processing takes place via the "Google Pay" application on your mobile end device, which must run at least Android 4.4 ("KitKat") and have NFC functionality, by charging a payment card stored in Google Pay or a payment system verified there (e.g. PayPal). To authorise a payment via Google Pay in excess of €25, you must first unlock your mobile device using the verification method you have set up (e.g. facial recognition, password, fingerprint or pattern).
For the purpose of payment processing, the information you provided during the ordering process, together with information about your order, is transmitted to Google. Google then transmits your payment information stored in Google Pay, in the form of a one-time transaction number, to the originating website, which is used to verify that a payment has been made. This transaction number contains no information relating to the actual payment data of the payment means stored by you in Google Pay, but is created and transmitted as a one-time valid numeric token. In all transactions via Google Pay, Google acts merely as an intermediary in processing the payment. The transaction is carried out exclusively between the user and the originating website, by debiting the payment means stored in Google Pay.
Insofar as personal data is processed in the course of the transmissions described, this processing takes place 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 every transaction made via Google Pay. This includes the date, time and amount of the transaction, the merchant's location and description, a description of the goods or services purchased provided by the merchant, photos you have attached to the transaction, the name and e-mail address of the seller and buyer, or 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 takes place exclusively in accordance with Art. 6 (1) (f) GDPR on the basis of the legitimate interest in proper invoicing, verification of transaction data, and optimisation and maintenance of the Google Pay service.
Google also reserves the right to combine the processed transaction data with further information collected and stored by Google when using other Google services.
The terms of use of Google Pay 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 with 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
One or more online payment methods from the following provider are available on this website: PayPal (Europe) S.a.r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg
If you select a payment method from the provider in which you pay in advance, your payment data 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 it in accordance with Art. 6 (1) (b) GDPR. In this case, your data is passed on exclusively for the purpose of payment processing with the provider and only to the extent necessary for this purpose.
If you select a payment method in which we pay in advance, you will also be asked during the ordering process to provide certain personal data (first and last name, street, house number, postal code, city, date of birth, e-mail address, telephone number, and, if applicable, data on an alternative payment method).
In order to safeguard our legitimate interest in determining your ability to pay, this data is passed on by us in accordance with Art. 6 (1) (f) GDPR to the provider for the purpose of a credit check. Based on the personal data you provide and further data (such as the shopping cart, invoice amount, order history, payment experience), the provider checks whether the payment method you have selected can be granted in view of the risk of non-payment and/or default.
The credit information may contain probability values (so-called score values). Insofar as score values are included in the result of the credit information, they are based on a scientifically recognised mathematical-statistical procedure. Among other things, but not exclusively, address data is used in the calculation of the score values.
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 nevertheless remain entitled to process your personal data insofar as this is necessary for the contractual processing of payments.
- 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 in which you pay in advance (such as credit card payment), your payment data 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 it in accordance with Art. 6 (1) (b) GDPR. In this case, your data is passed on exclusively for the purpose of payment processing with the provider and only to the extent necessary for this purpose.
If you select a payment method in which the provider pays in advance (such as purchase on invoice or in instalments, or direct debit), you will also be asked during the ordering process to provide certain personal data (first and last name, street, house number, postal code, city, date of birth, e-mail address, telephone number, and, if applicable, data on an alternative payment method).
In order to safeguard our legitimate interest in determining our customers' ability to pay, this data is passed on by us in accordance with Art. 6 (1) (f) GDPR to the provider for the purpose of a credit check. Based on the personal data you provide and further data (such as the shopping cart, invoice amount, order history, payment experience), the provider checks whether the payment method you have selected can be granted in view of the risk of non-payment and/or default.
The credit information may contain probability values (so-called score values). Insofar as score values are included in the result of the credit information, they are based on a scientifically recognised mathematical-statistical procedure. Among other things, but not exclusively, address data is used in the calculation of the score values.
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 nevertheless remain entitled to process your personal data insofar as this is necessary for the contractual processing of payments.
- WooCommerce Payments
One or more online payment methods from the following provider are available on this website: Automattic Inc., 60 29th Street #343, San Francisco, CA 94110-4929, USA
If you select a payment method from the provider in which you pay in advance (such as credit card payment), your payment data 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 it in accordance with Art. 6 (1) (b) GDPR. In this case, your data is passed on exclusively for the purpose of payment processing with the provider and only to the extent necessary for this purpose.
For data transfers to the USA, the provider has joined the EU-US Data Privacy Framework, which, on the basis of an adequacy decision of the European Commission, ensures compliance with the European level of data protection.
9) Web analytics services
Google (Universal) Analytics
This website uses Google (Universal) Analytics, a web analytics service provided by Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland ("Google"), which enables an analysis of your use of our website.
By default, when visiting the website, Google (Universal) Analytics sets cookies, which are stored as small text files on your end device and collect certain information. This information also includes your IP address, which is, however, shortened by Google by the last digits in order to rule out direct personal reference.
The information is transmitted to Google servers and further processed there. This may also involve transmission to Google LLC, based in the USA.
Google uses the collected information on our behalf to evaluate your use of the website, to compile reports on website activity for us, and to provide other services related to website usage and internet usage. The IP address transmitted by your browser as part of Google Analytics, once shortened, is not merged with other data from Google. The data collected as part of the use of Google (Universal) Analytics is stored for a period of two months and then deleted.
All of the processing described above, in particular the setting of cookies on the end device used, only takes place if you have given us your express consent in accordance with Art. 6 (1) (a) GDPR.
Without your consent, Google (Universal) Analytics is not used during your visit to the site. You can withdraw your consent at any time with effect for the future. To exercise your right of withdrawal, please deactivate this service via the "cookie consent tool" provided on the website.
We have concluded a data processing agreement with Google that ensures the protection of the data of our website visitors and prohibits unauthorised disclosure to third parties.
Further legal information on Google (Universal) Analytics can be found at https://business.safety.google/intl/de/privacy/, https://policies.google.com/privacy?hl=de&gl=de and at https://policies.google.com/technologies/partner-sites
Demographic characteristics
Google (Universal) Analytics uses the special "demographic characteristics" function and can use it to compile statistics that provide information on the age, gender and interests of website visitors. This is done by analysing advertising and information from third-party providers. This allows target groups to be identified for marketing activities. However, the data collected cannot be assigned to a specific person and is deleted after a storage period of two months.
Google Signals
As an extension of Google (Universal) Analytics, Google Signals may be used on this website to generate cross-device reports. If you have activated personalised advertising and linked your devices to your Google account, Google, subject to your consent to the use of Google Analytics in accordance with Art. 6 (1) (a) GDPR, may analyse your usage behaviour across devices and create database models, including cross-device conversions. We do not receive any personal data from Google, only statistics. If you wish to stop cross-device analysis, you can deactivate the "Personalised advertising" function in your Google account settings. To do this, follow the instructions on this page: https://support.google.com/My-Ad-Center-Help/answer/12155764?hl=de
Further information on Google Signals can be found at the following link: https://support.google.com/analytics/answer/7532985?hl=de
UserIDs
As an extension of Google (Universal) Analytics, the "UserIDs" function may be used on this website. If you have consented to the use of Google (Universal) Analytics in accordance with Art. 6 (1) (a) GDPR, have set up an account on this website, and log in on various devices with this account, your activities, including conversions, can be analysed across devices.
For data transfers to the USA, the provider has joined the EU-US Data Privacy Framework, which, on the basis of an adequacy decision of the European Commission, ensures compliance with the European level of data protection.
10) Retargeting/remarketing and conversion tracking
Meta Pixel
As part of our online offering, we use the "Meta Pixel" service provided by the following provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland ("Meta")
If a user clicks on an advertisement placed by us on Facebook and/or Instagram, "Meta Pixel" adds a parameter to the URL of our linked page. After the redirect, this URL parameter is then written into the user's browser via a cookie set by our own linked page.
This allows Meta, on the one hand, to determine visitors to our online offering as a target group for the display of advertisements (so-called "Ads"). Accordingly, we use this service to display the Facebook and/or Instagram ads placed by us only to those 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 on the basis of the websites visited) that we transmit to Meta (so-called "Custom Audiences").
On the other hand, "Meta Pixel" can be used to trace whether users were redirected to our website after clicking on an advertisement and what actions they take there (so-called "conversion tracking").
The data collected is anonymous to us, meaning it does not provide us with any information about the identity of the users. However, the data is stored and processed by Meta, so that a connection to the relevant user profile is possible, and Meta can use the data for its own advertising purposes.
All of the processing described above, in particular the setting of cookies for reading information on the end device used, only takes place if you have given us your express consent in accordance with Art. 6 (1) (a) GDPR. You can withdraw 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 that ensures the protection of the data of our website visitors and prohibits unauthorised disclosure to third parties.
The information generated by Meta is generally transmitted to a Meta server and stored there; in this context, transmission to servers of Meta Platforms Inc. in the USA may also occur.
For data transfers to the USA, the provider has joined the EU-US Data Privacy Framework, which, on the basis of an adequacy decision of the European Commission, ensures compliance with the European level of data protection.
11) Tools and other matters
Cookie consent tool
This website uses a so-called "cookie consent tool" to obtain valid user consent for cookies requiring consent and cookie-based applications. The "cookie consent tool" is displayed to users when they access the page in the form of an interactive user interface, on which consent can be given for certain cookies and/or cookie-based applications by ticking boxes. By using this tool, all cookies/services requiring consent are only loaded once the respective user has given the corresponding consent by ticking the relevant box(es). This ensures that such cookies are only placed on the respective user's end device if consent has been given.
The tool sets technically necessary cookies in order to store your cookie preferences. Personal user data is generally not processed in this connection.
If, in individual cases, personal data (such as the IP address) is nevertheless processed for the purpose of storing, assigning or logging cookie settings, this takes place in accordance with Art. 6 (1) (f) GDPR on the basis of our legitimate interest in legally compliant, user-specific and user-friendly consent management for cookies, and thus in the legally compliant design of our internet presence.
A further legal basis for the processing is also Art. 6 (1) (c) GDPR. As controller, we are subject to the legal obligation to make the use of technically unnecessary cookies dependent on the respective user's consent.
Where necessary, we have concluded a data processing agreement with the provider that ensures the protection of the data of our website visitors and prohibits unauthorised disclosure to third parties.
Further information on the operator and the setting options of the cookie consent tool can be found directly in the corresponding user interface on our website.
12) Rights of the data subject
12.1 Under applicable data protection law, you have the following rights as a data subject vis-à-vis the controller with regard to the processing of your personal data (rights of access and intervention), whereby reference is made to the relevant legal basis for the respective conditions of exercise:
- right of access in accordance with Art. 15 GDPR;
- right to rectification in accordance with Art. 16 GDPR;
- right to erasure in accordance with Art. 17 GDPR;
- right to restriction of processing in accordance with Art. 18 GDPR;
- right to notification in accordance with Art. 19 GDPR;
- right to data portability in accordance with Art. 20 GDPR;
- right to withdraw consent given, in accordance with Art. 7 (3) GDPR;
- right to lodge a complaint in accordance with Art. 77 GDPR.
12.2 RIGHT TO OBJECT
IF, AS PART OF A BALANCING OF INTERESTS, WE PROCESS YOUR PERSONAL DATA ON THE BASIS OF OUR OVERRIDING LEGITIMATE INTEREST, YOU HAVE THE RIGHT AT ANY TIME TO OBJECT TO THIS PROCESSING WITH EFFECT FOR THE FUTURE, FOR REASONS ARISING FROM YOUR PARTICULAR SITUATION.
IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL CEASE PROCESSING THE DATA CONCERNED. WE RESERVE THE RIGHT TO FURTHER PROCESSING, HOWEVER, IF WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING WHICH OVERRIDE YOUR INTERESTS, RIGHTS AND FREEDOMS, OR IF THE PROCESSING SERVES THE ASSERTION, EXERCISE OR DEFENCE OF LEGAL CLAIMS.
IF YOUR PERSONAL DATA IS PROCESSED BY US 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 MAY EXERCISE YOUR RIGHT TO OBJECT AS DESCRIBED ABOVE.
IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL CEASE PROCESSING THE DATA CONCERNED FOR DIRECT MARKETING PURPOSES.
13) Duration of storage of personal data
The duration of the storage of personal data is measured according to the respective legal basis, the purpose of processing and – where applicable – additionally according to the respective statutory retention period (e.g. retention periods under commercial and tax law).
Where personal data is processed on the basis of express consent in accordance with Art. 6 (1) (a) GDPR, the data concerned is stored until you withdraw your consent.
Where statutory retention periods exist for data processed in the context of contractual or quasi-contractual obligations on the basis of Art. 6 (1) (b) GDPR, this data is routinely deleted after the retention periods have expired, provided it is no longer required for the performance or initiation of a contract and/or we no longer have a legitimate interest in its continued storage.
Where personal data is processed on the basis of Art. 6 (1) (f) GDPR, this data is stored until you exercise your right to object in accordance with Art. 21 (1) GDPR, unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves the assertion, exercise or defence of legal claims.
Where personal data is processed for direct marketing purposes on the basis of Art. 6 (1) (f) GDPR, this data is stored until you exercise your right to object in accordance with Art. 21 (2) GDPR.
Unless otherwise indicated by the other information in this policy about specific processing situations, stored personal data will otherwise be deleted once it is no longer necessary for the purposes for which it was collected or otherwise processed.

