Data Privacy Policy

Protecting your data is very important to us. Therefore, when you use our website or the EMP app for iOS or Android, we will, of course, comply with applicable provisions of data protection law in accordance with the following data privacy policy.


Protecting your data is very important to us. Therefore, when you use our website or the EMP app for iOS or Android, we will, of course, comply with applicable provisions of data protection law in accordance with the following data privacy policy.

1 Data controller

EMP Mail Order UK Ltd.
c/o Francis Clark LLP
North Quay House
Sutton Harbour
United Kingdom


Data protection officer:


André Bosse

Darmer Esch 70a

49811 Lingen


phone: 05 91 - 9 14 310



The data protection officer is a DEKRA certified "data protection specialist."


To be certified as a "data protection specialist", the data protection officer must demonstrate his or her subject matter knowledge in a written examination. DEKRA certification is limited to a certain time period and may be renewed by taking subsequent tests at regular intervals or by furnishing proof of enrollment in continuing education events. The certification is issued by DEKRA Certification GmbH, Handwerkstr. 15, 70565 Stuttgart, GERMANY.



The required subject matter knowledge is detailed at and includes, inter alia, the following:


  • Provisions and implementation of the European General Data Protection Regulation (EU GDPR)
  • Provisions and implementation of the revised Federal Data Protection Act (BDSG, neu)
  • Data security and IT security: technical and organizational measures
  • Risk management
  • Data protection management – organization of data protection within the company
  • Principles governing the processing of personal data
  • Data protection officer (internal/external)
  • Rights of data subjects
  • Notification obligations
  • and more (see link).


These requirements are satisfied by our data protection officer. According to the DEKRA seal, the certification is currently valid until January 2020.


2 Collected data and purpose of data use


We will collect personal data on the basis of your consent, to perform contracts with you and/or to perform legal obligations. Personal data include any information related to an identified or identifiable natural person.


2.1 Usage data


When you visit our website or use the EMP app, we will collect usage data (for example, your browser, times of access, product pages you visit, device data, version of the app, etc.) for statistical purposes, to optimize our products and services, and to guarantee system security.


2.2  Data collected when you place an order as a non-registered user


If you place an order without registering ("order as a guest"), we will store the personal data we need to process the transaction (name, address, e-mail address, payment information).  In addition, you may provide us with your telephone number, so that we can reach you more quickly if we have any questions. If you have filled out the optional field "date of birth," we will also send you our birthday special. Guest customers also benefit from our international customer service.


We will process your personal data to process and fill your order and to optimize our products and customer services. To process and fill your order, to ship products, or to process and maintain customer data, we will transfer personal data to specialized service providers, such as shipping companies.


2.3 Data collected when you place an order as a registered user


Ordering from EMP is very convenient. We offer free registration – in which case your personal data will be stored in a password-protected customer account independently of any particular order. Your EMP customer account will simplify the ordering process and offers the following:


  • Products will be placed in your shopping basket, allowing you to continue shopping
  • There is no need for you to reenter your data every time you place an order
  • You have access to your data from anywhere and can use the international customer service of EMP
  • You can change your personal data under "Your Account" or delete your customer account in the Online Shop (see below)
  • Registration is absolutely free and requires no purchase on your part.


To create a customer account, we will need your name and your e-mail address. In addition, you may provide your telephone number and your date of birth. You may view your customer account and the data stored in your account at any time. You can do so in your personal area under "Your Account" (after you have logged in). To delete your customer account in the Online Shop, please use the link "Delete Account." Please note that if you delete your account, data that have been collected for your customer account will be erased from the customer account in the Online Shop unless they are needed for filling open orders and/or to perform legal obligations, and that if you were to place a new order, you would have to reenter your data.


To prevent any misuse of your customer account, be sure to log out from your customer account after every session/registration. Some browsers allow you to save the username and password and to automatically fill in this information the next time you access the login page. Especially when you use a public computer or if you share a computer with another user, you should keep this in mind.


If you want to become a member of the Backstage Club, you will first have to create a customer account. Data collected by us will then also be processed for the services offered to members of the Backstage Club.


2.4 International Customer Service


We provide you with the simplest, most convenient and comprehensive customer service possible. The international customer service of all EMP companies is at your disposal for order mamagement. EMP companies include E.M.P. Merchandising HGmbH, EMP Mail Order UK Ltd, Emp Mailorder Italia S.r.l., Large Popmerchandising B.V. and Large Popmerchandising B.V.B.A..


Therefore, you can not only contact the EMP company where you placed your order, but also any other EMP company for service requests. They process your customer data to manage your service requests.


The EMP company with whom you placed the order transmits your data to the other EMP companies so that they have access to your order data in case of service.


If you use our contact form to contact us with a service request, we collect the data required for contacting us (name, e-mail address). Optionally, you can also enter your customer number and address so that we can process your service request more effectively and quickly.


2.5 Marketing purposes, e.g., magazine subscription


In addition, we will use your personal data for our own marketing purposes (e.g., mailing of our magazine). If you subscribe to our magazine, we will collect your name and address. We will also collect additional, optional personal data (date of birth, e-mail address, telephone number, how you found out about us), if you so choose.


3 EMP e-mail newsletter


We offer you to subscribe to our free EMP e-mail newsletter. If you subscribe, you will receive e-mails with information about our products and services, including new products and services, and information about special offers at regular intervals.


By providing your e-mail address, checking the consent box, and then clicking on the button "Register", you will consent that EMP Merchandising Handelsgesellschaft mbH, Darmer Esch 70a, 49811 Lingen, may use your e-mail address for e-mail marketing purposes as follows:


I hereby consent to receive the EMP Newsletter and consent that E.M.P. Merchandising mbH may process my personal data and send me information about its products on a regular basis. My personal data will be processed in conformity with the provisions of the Data Privacy Policy [please include hyperlink]. I may revoke my consent at any time by notifying E.M.P. Merchandising mbH.


You may also choose to provide additional information when you subscribe to the newsletter. Such information includes your first name and last name, your date of birth, and your personal interests with respect to which you would like to receive information from us.


After you have subscribed to our newsletter, you will receive an e-mail from us. To complete your subscription to our newsletter, you will have to click on the activation link in that e-mail. Your e-mail address will then be permanently stored and will not be transferred to third parties.


To send you information as part of our newsletter that is tailored specifically to your personal interest, we will analyze how you use the Online Shop, i.e., which of our products and services you look at or order. We will use this analysis for no other purposes and will not transfer that information to any third parties. We use cookies to track usage of our website. Most browsers accept cookies by default. You can allow or block session cookies and persistent cookies independently from one another by selecting the appropriate security settings in your browser. If you block cookies, certain features of our website may under certain circumstances no longer be available to you and some websites may not be displayed correctly.


To improve our newsletter, will also use the e-mail analysis service of Emarsys, a service offered by Emarsys Interactive Services GmbH. For this purpose we will track your personal reader preferences by analyzing whether e-mails are opened and which links are clicked. To track the opening of e-mails, the newsletter will retrieve a special graphic file from the server. Additional information about data protection at Emarsys is available here:


If you no longer wish to receive our newsletter, you may at any time unsubscribe from the newsletter. Each issue of our newsletter will include an unsubscribe link at the end, which makes unsubscribing easy, convenient, and free. You can also unsubscribe from the newsletter by sending an informal notice to the e-mail address If you unsubscribe from the newsletter, all data you have provided for subscribing to the EMP newsletter will be erased.


4 E-mail advertising within the meaning of § 7 para. 3 of the German Unfair Competition Act (UWG)


To the extent permitted by law under § 7 para. 3 of the German Unfair Competition Act (UWG), we may use the e-mail address that you have provided to purchase a product or service in exchange for payment, for sending you advertisements of other, similar products or services we offer. If you no longer wish to receive advertising of similar products and services, you may object to such use of your e-mail address at any time without incurring any transmission charges other than the standard rates. To opt out of product recommendations, you may click on the unsubscribe-link that is included in each mailing.


5 Transfer of data to third parties


Personal data will be transferred to third parties only if this is necessary for their intended purposes. We will transfer your personal data to the shipping company to ship your order and to the payment service provider you have selected to process payment. Your data will not be transferred to third parties for any other purposes (e.g., marketing purposes of third parties).


Your data will be transferred to third countries only if we have expressly advised you thereof in this data privacy policy. If we do so, we will take appropriate measures to make sure that the third parties to which your data are transferred provide an adequate level of protection for personal data.


6 Erasure of data


Personal data stored by us will be erased if one or several of the following occurs:


  • You have revoked your consent to data processing;
  • Data are no longer needed to achieve the purpose of data storage; or
  • Storage is or becomes unlawful for other legal reasons.


However, if your data are erased or blocked, you will no longer be able to use certain services. We will not erase data if and to the extent that we have legal recordkeeping obligations.


7 Your rights


Upon your request we will inform you which of your personal data are stored by us. Information may also be provided electronically. Upon your request we will also rectify, block, or erase your personal data that are stored by us. Your right to erase personal data may be precluded by legal recordkeeping obligations. You have the right to revoke your consent to the processing of your personal data at any time with future effect. Revocation will not affect the lawfulness of data processing that occurs before consent is revoked.


You have the right to demand that we make available to you or transfer to other controllers in machine-legible form your data which you have provided to us and which we process by automated method or to the use of which you have consented.


You may also object to the use, processing, or transfer of your personal data, including, without limitation, for direct advertising purposes (e.g., e-mail advertising or magazine), at any time by notifying our data protection officer (at the above address or by sending an e-mail to This will result in no transmission charges other than the standard rates. After receiving your objection, we will no longer use or process the data in question for direct advertising purposes and we will promptly stop sending you any further advertising, including our magazine.


You may also lodge a complaint with the competent data protection regulatory authority ICO


8 Security and encryption


We will protect your personal data against risks associated with data processing. For this purpose we maintain appropriate, state-of-the-art technical and organizational measures.


Our security server software (secure sockets layer – SSL) will encrypt all of your personal data, such as your name, address, and credit card number. Such information cannot be viewed by unauthorized third parties during transmission via the Internet. Our security server software (secure socket layers – SSL) will encrypt data you enter so that they can be securely transferred via the Internet.


9 Payment by invoice – transfer of data to Klarna


By selecting the payment option "payment by invoice" you consent that we may collect the following personal data that are required for processing the purchase with payment by invoice and for running an identity and credit check, such as your first name and last name, address, date of birth, gender, e-mail address, telephone number, as well as data that are required for processing the purchase with payment by invoice and are related to the order, such as the number of products, product numbers, invoice amount, and taxes in percentage, and transfer such data to Klarna GmbH, Theresienhöhe 12, 80039 Munich (hereinafter "Klarna"). Such data will be transferred to allow Klarna to process your purchase using the payment method you have selected, to invoice you, and to run an identity and credit check. Klarna has a legitimate interest in the transfer of the purchaser's personal data and needs such data for purposes of obtaining information about the purchaser's identity and credit score from the appropriate credit rating agencies. You will find additional information about credit rating agencies with whom Klarna cooperates in the data privacy policy of Klarna. In connection with the decision of whether to enter into, perform, or terminate the contract Klarna also collects and uses, apart from verifying the address, information regarding the purchaser's past payment behavior and probability data regarding future payment behavior. Scores are calculated by Klarna based on a scientifically recognized, mathematical-statistical method. For this purpose Klarna will also use your address data. Should this calculation show that your credit rating is insufficient, Klarna will promptly notify you.


You may at any time revoke your consent to Klarna's use of your personal data by notifying Klarna. However, even if you revoke consent, Klarna will continue to have the right to process, use, and transfer personal data if and to the extent necessary for processing payment using Klarna's services, required by law, or ordered by a court or regulatory authority.


10 Contests


If you participate in a contest, we will collect the personal data you have provided for purposes of the contest.


If you win a contest, E.M.P. Merchandising Handelsgesellschaft mbH will generally publish your name. To notify you of the outcome of a contest, we will send you an e-mail to the e-mail address you have provided.


Personal data of participants will be processed for purposes of holding the contest and for statistical purposes by E.M.P. Merchandising Handelsgesellschaft mbH.


Stored personal data will be erased when they are no longer needed for holding the contest or if storage is or becomes unlawful for other legal reasons.


11 Facebook Connect and Google+ Sign-In


To register on our website you can use "Facebook Connect," a service of Facebook Inc., 1601 S. California Ave., Palo Alto, CA 94304, U.S.A. (hereinafter "Facebook"). If you register with Facebook Connect, your profile on our website will be linked to your profile on Facebook. If you use Facebook Connect, you can use your Facebook login data to register on our website. In that case, your Facebook user ID will be sent to us and linked to your user account on our website. In addition, you hereby grant us permission to send you e-mails to the e-mail address associated with your Facebook account. For information about your data, data collection, and protection of your privacy, please refer to the data privacy policy of Facebook. If you do not wish your Facebook profile to be linked to your user account, do not use Facebook Connect.


You may also register on our website using Google+ Sign-In, a service of Google, Inc. (hereinafter "Google"). If you use Google+ Sign-In, data you provide will be processed and stored by us exclusively for purposes of your registration. Use of Google+ Sign-In is subject to the data privacy policy and general terms and conditions of Google. When you use Google+ Sign-In, your Google+ registration information (including personal data such as your name, e-mail address, telephone number, and other information that you have provided as part of your Google+ profile) will be transferred by Google to EMP. For additional information about Google+ Sign-In and about the administration of your Google+ access rights, please click here.


If you do not consent to such data transfer, please use your EMP account instead of Facebook Connect or Google + Sign-In to register.


12 Social plugins


We use social plugins (hereinafter "plugins") of social networks.


For greater protection of your data when using our website plugins are not integrated into our website without restriction, but merely by using an HTML link (so-called "shariff plugin"). This type of integration ensures that just by using our website no connection to the service of the social network provider will be established yet. If you click on a button of a social network, a new window will open and access the page of the service provider, where you can then (where applicable, after entering your login data) click, for example, on the like button or share button.


For the purpose and scope of data collection and the further processing and use of data by social network providers on their respective websites, and for your related rights and setting options to protect your privacy, please refer to the data privacy policies of the following providers:


13 Userlike live chat


Our website offers the option of Userlike, live chat software of the company Devcores UG (haftungsbeschränkt) (hereinafter "Userlike"). Userlike uses cookies that will be stored on your computer and allow personal conversations with you in the form of real-time chats on the website. When using the chat function, the chat, including the pages viewed, will be collected, processed and stored by Userlike in Germany. For additional information about the data privacy policy of Userlike, please click here.


14 Cookies and tracking


Cookies are small text files that are stored by your browser on the hard drive of your computer. Our cookies contain no personal information of any kind and merely serve navigation and recognition purposes.


We use two types of cookies: "persistent cookies" that remain on your computer for a longer time period, and "session cookies" that are immediately deleted as soon as you close your browser. Permanent cookies help us recognize you the next time you visit our website. You can however manually delete such cookies in your browser if you like. Session cookies are important, for example, for you to be able to place products into your shopping cart during your visit and for keeping those products in your shopping card until you are ready to place your order. Cookies also help us analyze how customers use our Online Shop. This helps us continuously optimize and improve the Online Shop.


Most browsers accept cookies by default. You can allow or block session cookies and persistent cookies independently from one another by selecting the appropriate security settings in your browser. If you block cookies, certain features of our website may under certain circumstances no longer be available to you and some websites may not be displayed correctly.


14.1 Google Analytics


Our website uses Google Analytics, a web analysis service of Google. Google Analytics uses cookies that are stored on your computer and allow an analysis of your use of the website.


Information about your use of this website generated by cookies generally will be transferred to a server of Google in the United States and stored there. If IP anonymization is activated on this website, your IP address will however first be truncated by Google in member states of the European Union or in other signatory states to the Agreement on the European Economic Area. Note that Google Analytics has been configured on this website so that IP addresses will be tracked anonymously (so-called IP masking). Only in exceptional cases will the full IP address be transferred to a Google server in the United States and masked there. On behalf of the operator of this website Google will use that information to analyze your use of the website, to compile reports about website activities, and to provide additional services to the website operator related to website use and Internet use. The IP address transmitted by your browser in connection with Google Analytics will not be merged with any other data of Google. You may block cookies by selecting the appropriate settings in your browser; please note, however, that if you block cookies you may no longer be able to fully use all functions of this website.


We also use Google Analytics advertising features to track impressions in the Google display network. For this purpose website data are enriched with non-personal data of our Google advertising products.


You can prevent the tracking of data about your use of the website (including your IP address) generated by cookies and the tracking of data from Google advertising products and processing of such data by Google by downloading and installing a browser plugin that is available at the following link:


14.2 Google Conversion Tracking


The success of our advertising campaigns using Google Adwords is measured by Google Conversion Tracking, a tool of Google Inc., 1600 Amphitheater Pkwy., Mountain View, CA 94043 (hereinafter "Google"). If you are transferred to our website through a Google ad, a cookie will be placed on your computer. Via such cookies we receive feedback on which products and services on our websites are used by our customers. Cookies are automatically deleted after 30 days. No personal data are transmitted to us in this connection. If you want to deactivate cookies for conversion tracking, you can select the appropriate settings in your browser so that cookies from the domain "" will be blocked.


14.3 Google remarketing


We use Google remarketing for our Online Shop, a Google program for interest-based advertising. On the basis of cookies that have been stored for this purpose during prior visits to our Online Shop we can run online advertisements that are geared towards the interests of users. Such ads are either for products that you have already viewed or products that may interest you based on your purchasing and browsing behavior.


You can, of course, deactivate the use of cookies by Google for those purposes:


In the alternative, you can also deactivate the use of cookies by third-party providers in general:


You can find additional notices and information about the data privacy policy of Google here:


14.4 Criteo retargeting


We use retargeting technology of Criteo GmbH, Gewürzmühlstr. 11, 80538 Munich, (hereinafter "Criteo"),= for our website. This technology collects information about the browsing behavior of website visitors for marketing purposes in anonymous form and places cookies for this purpose. This allows Criteo to analyze browsing behavior and on that basis display specific product recommendations in the form of appropriate advertising banners when other websites are visited. Under no circumstances can anonymous data be used to identify visitors to the website. Data collected by Criteo will merely be used to improve advertised products and services. Each display banner will include, in the lower right-hand corner, a small "i" (which stands for "information"), which when you mouse over it will open and which when clicked will transfer you to a page on which the system is explained and an opt-out is offered. If you click on "opt-out" [please insert link for opt-out cookie], an opt-out cookie will be placed preventing such banners from being displayed in the future. Data will not be used for any other purposes or transferred to any third parties.


You will find additional information about the data privacy policy of Criteo here:


14.5 Webtrekk


We use the services of Webtrekk GmbH, Robert-Koch-Platz 4, 10115 Berlin (hereinafter "Webtrekk") for statistically tracking usage of our website. For this purpose some information about your website visit will be tracked and transmitted by your browser. The following data will be collected: request (file name of requested file), browser type/version (e.g., Firefox 29), browser language (e.g., German), operating system used (e.g., Windows 8), internal resolution of browser window, monitor resolution, JavaScript activation, Java on/off, cookies on/off, color depth, referrer URL (previously visited website), IP address (will be promptly rendered anonymous and deleted immediately after use), time of access, clicks, order amounts, if any, and content of completed forms, if any (for user-defined text fields, e.g., name and password, only "filled out "or "not filled out" will be transferred).


For statistical analysis purposes we anonymously track shopping carts and orders and transmit such data to Webtrekk.


On the website you can use certain forms to transmit data to us. Unless personal data are involved, data you enter into forms will be stored and statistically analyzed. If personal data are involved, only cancellation or successful transmission will be tracked for statistical purposes, unless you expressly permit us to analyze your data for statistical purposes.


You may at any time opt out of data collection and storage by Webtrekk by clicking on the following link

. An opt-out cookie will then be placed and will be valid for five years, preventing any collection of your data.


Please note that this cookie will be activated only for the particular browser and the particular terminal device used and that you must opt out separately for any additional browsers or terminal devices. This also applies if all cookies on your terminal device are deleted.


14.6 AdClear


We use the services of AdClear GmbH, Robert-Koch-Platz 4, 10115 Berlin (hereinafter "AdClear") on our website to collect statistical data for campaign tracking in an effort to optimize our products and services for our customers. For this purpose cookies are used. Data are tracked exclusively in pseudonymous form. No personal data will be sent to AdClear. AdClear's campaign tracking service is data protection certified by TÜV Saarland.


You may opt out of AdClear campaign tracking. If you do so, a cookie named "adclearoptout" will be placed by the domain Your opt-out will be valid as long as you do not delete the cookie. To do so, please click here


14.7 Facebook Pixel


We use Facebook Custom Audience Pixel, a service of Facebook, on our website. A cookie is placed that allows us to understand how our marketing is received on Facebook and can be improved.


For example, your behavior can be tracked after you are transferred to the website of a seller by clicking on a Facebook ad. The purpose is to analyze the effectiveness of Facebook ads for statistical and market research purposes and thereby to optimize future advertising.


Data that are collected in this connection are anonymous for us and thus allow us to make no inferences as to your identity. However, data will be stored and processed by Facebook, so that they may be linked to your user profile and Facebook may use such data for its own advertising purposes in accordance with the Facebook data use policy ( This may allow Facebook and its business partners to run advertisements on or off Facebook.


14.8 Dynatrace Performance Monitoring


We use Dynatrace Performance Monitoring, a web service of Dynatrace LLC, on our website. The service monitors the performance of web applications. When the service is used, your data will be immediately rendered anonymous. You can find additional information about data privacy at Dynatrace Performance Monitoring here:


14.9 Salesforce Commerce Cloud Analytics


We use Salesforce Commerce Cloud Analytics, a service of Salesforce Germany GmbH, for our website. The service manages user transaction data from our website. Collected and indexed data can be analyzed. For example, indexed data can be categorized or aggregated, shown in various diagrams and graphics, or supplemented with additional data or information.


You can find additional information about data privacy at salesforce here:


14.10 All Response Media


We use All Response Media Ltd. for our analysis and optimisation and they utilise your non-personal data to plan and optimise media campaigns to most effectively deliver our marketing strategies and ensure the ads that you receive from us are relevant to you. They do this through Performance, Analysis and Targeting cookies.


‘Performance’ cookies collect information about how the publisher’s website works e.g. which pages you visit, and if you experience any errors. These cookies do not collect any information that could identify you as an individual – all the information collected is anonymous and is used to help us improve how the website works. PLATFORMS: GOOGLE ANALYTICS



‘Analysis’ cookies are used to profile user behaviour and optimise marketing campaigns e.g. we may track which creative and medium has more resonance with the target audience. This is designed to ensure relevant ads are served to you, to deliver a better experience with the brand. PLATFORMS: TAG4ARM, DOUBLECLICK*, CARBON**, FACEBOOK



‘Targeting’ cookies use the insight from the analysis to match the user with the relevant product and services. This includes retargeting a user as part of a digital audience (a grouping of cookies with similar interests based on the insight - not an individual) after they visited our publisher’s websites. PLATFORMS: DOUBLECLICK*, CARBON**, FACEBOOK



*Please note that through DoubleClick media partner cookies are housed that are dependent on agreed media activity in any given month. For example, this includes but is not limited to, Google, Facebook, DoubleClick Bid Manager, Sizmek etc. **Please note that Carbon utilises Neilson and the DoubleClick Bid Manager to facilitate ad serving.



Further detail of the related cookies can be noted in the Cookie Policy on this website and


All Response Media’s website.


14.11 Crashlytics

We use the service Crashlytics from Google (Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA) to collect information about errors and crashes which occur in our iOS and Android apps. This helps us to improve the stability and quality of our app. Crashlytics processes data such as your Android device ID. The information transferred from our app is stored on the Crashlytics servers in the USA. You can find more information on data protection on the Crashlytics site


15 eKomi


We use the independent evaluation Portal eKomi, which is operated by eKomi Ltd., Markgrafenstr. 11, 10969 Berlin, Germany. We constantly want to improve ourselves and our service and for this reason we have decided to use such a solution. Accordingly, it is not possible for us to control or influence evaluation invitations individually. When you place an order with us, you will automatically receive an email from us afterwards with a link to evaluate your shopping experience with us. This is the only way to ensure a complete, independent and uninfluenced customer evaluation of our company and our services. The data passed on to eKomi: [Order-ID, Date and Time of the order] will be used by eKomi itself or passed on to third parties to fulfill the contract. The evaluation is free of charge to you as a customer. By submitting the evaluation/feedback, you agree to the current communication rules of eKomi. If you have any questions regarding the collection, processing or use of your personal data, information, rectification, blocking or deletion of data and revocation of any given consent or opposition to a certain data use please contact us at:

15.9 Data Protection Notice to transfer E-Mail addresses to Funko and Direct Marketing Consent

E.M.P. Merchandising Handelsgesellschaft mbH ("EMP", "we" or "our") provides this Data Protection Notice ("Notice") to explain our practices as the responsible data controller regarding the processing of your email addresses in the context of transferring them to our business partner Funko UK Limited, 21 Holborn Viaduct, London, United Kingdom, EC1A 2DY ("Funko").


EMP collects, processes, and uses your email address as part of your check-out process during the purchase of Funko products on the EMP Website.


You are in the process of purchasing Funko products on our Website. For the purposes of inter alia delivering the Funko products, providing customer care services, compliance with legal obligations and defending, establishing and exercising legal claims we process your email address in accordance with our Website Privacy Policy which you can find here:Privacy Policy.

In addition to that and based on your explicit and voluntary consent in accordance with Art. 6 (1) lit. (a) General Data Protection Regulation ("GDPR") provided on the basis of this Notice, we will transfer your email address to Funko after September 2021. Funko will process your email address to send you marketing information about other Funko products and services, new developments, and their events via email.

The provision of your email address for the transfer to Funko is voluntary and is not required as part of the purchase. Not providing it will not result in any disadvantages for you and will especially not result in legal consequences for you.


Funko is located in the UK (London) and depending on the outcome of the Brexit process will be located outside the European Economic Area ("EEA") from March 29, 2019 onwards. In case of a hard Brexit the UK will be considered a country which does not adduce an adequate level of protection from a European data protection law perspective. We will take all necessary measures to ensure that transfers out of the EEA are adequately protected as required by applicable data protection law by basing the transfer on appropriate safeguards, such as standard data protection clauses adopted by the European Commission or by a supervisory authority, approved codes of conduct together with binding and enforceable commitments of Funko. You can ask for a copy of such appropriate safeguards by contacting us as set out in the "Questions" section below.


Your email address is stored by EMP strictly for the time necessary to achieve the purposes for which the information is collected, in accordance with applicable data protection laws. After the transfer of your email address to Funko in October 2021 and if EMP no longer needs to use your email address for other purposes (as set out in our Website Privacy Policy), we will remove it from our systems and records and/or take steps to properly anonymize it so that you can no longer be identified from it (unless we need to keep your information to comply with legal or regulatory obligations to which EMP is subject).

15.9.5. YOUR RIGHTS Right to withdraw your consent

If you have declared your consent to the transfer of your email address to Funko and the receipt of certain type of direct marketing communication via email from Funko, you can withdraw this consent at any time with future effect. Such a withdrawal will not affect the lawfulness of the processing prior to the consent withdrawal. Please contact us as stated in the "Questions" section below to withdraw your consent or contact Funko ( You may also use the "unsubscribe" button in each email provided by Funko. Additional data privacy rights

Pursuant to applicable data protection law you may have the right to: (i) request access to your personal data; (ii) request rectification of your personal data; (iii) request erasure of your personal data; (iv) request restriction of processing of your personal data; (v) request data portability; and (vi) object to the processing of your personal data (including objection to profiling).

Please note that the aforementioned rights might be limited under the applicable national data protection law. Below please find further information on your rights under the GDPR:

5.2.1 Right of access: You may have the right to obtain from us confirmation as to whether or not personal data concerning you is being processed, and, where that is the case, to request access to the personal data. The access information includes – inter alia – the purposes of the processing, the categories of personal data concerned, and the recipients or categories of recipient to whom the personal data have been or will be disclosed. However, this is not an absolute right and the interests of other individuals restrict your right of access.

You may have the right to obtain a copy of the personal data undergoing processing. For further copies requested by you, we may charge a reasonable fee based on administrative costs.

5.2.2 Right to rectification: You may have the right to obtain from us the rectification of inaccurate personal data concerning you. Depending on the purposes of the processing, you may have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

5.2.3 Right to erasure (right to be forgotten): Under certain circumstances, you may have the right to obtain from us the erasure of personal data concerning you and we may be obliged to erase such personal data.

5.2.4 Right to restriction of processing: Under certain circumstances, you may have the right to obtain from us restriction of processing your personal data. In this case, the respective data will be marked and may only be processed by us for certain purposes.

5.2.5 Right to data portability: Under certain circumstances, you may have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and you may have the right to transmit those data to another entity without hindrance from us.

5.2.6 Right to object:Under certain circumstances, you may have the right to object, on grounds relating to your particular situation, at any time to the processing of your personal data by us and we can be required to no longer process your personal data. Such right to object may especially apply if EMP or Funko processes your personal data for direct marketing via email. If you have a right to object and you exercise this right, your personal data will no longer be processed for such purposes by us. You may exercise this right without incurring any costs other than the transmission costs in accordance with the basic tariffs of your telecommunication provider by contacting us as stated in the "Questions" section below.

Such a right to object may not exist, in particular, if the processing of your personal data is necessary to take steps prior to entering into a contract or to perform a contract already concluded.

If you have also consented to direct marketing but no longer want to receive any direct marketing via email, you also need to withdraw your consent as explained above .

To exercise your rights please contact us as stated in the "Questions" section below.

You also have the right to lodge a complaint with the competent data protection supervisory authority.


If you have any questions about this Notice or if you want to exercise your rights as explained in the "Your Rights" section, please contact

EMP's data protection officer can be contacted at E.M.P. Merchandising Handelsgesellschaft mbH, André Bosse, Darmer Esch 70a, D-49808 Lingen,

In case of exclusive purchase of Funko products (e.g., shopping cart contains only Funko products) you receive the option to give your consent to transfer your email address to Funko UK Limited, 21 Holborn Viaduct, London, United Kingdom, EC1A 2DY and to receive marketing information from Funko as of October 2021.You can obtain the related data protection information here: Privacy Policy.

If you have declared your consent to the transfer of your email address to Funko and the receipt of certain type of direct marketing communication via email from Funko, you can withdraw this consent at any time with future effect. Such a withdrawal will not affect the lawfulness of the processing prior to the consent withdrawal. Please contact us as stated in the "Questions" section below to withdraw your consent or contact Funko ( You may also use the "unsubscribe" button in each email provided by Funko.