(effective from 19 November 2018)
1. Data protection at a glance
Data collection on our website
Who is responsible for data collection on this website?
Data is processed on this website by the website operator, whose contact information is listed in the legal notice on this website.
How do we collect your data?
We collect your data when you provide it to us, for example when you enter data into a contact form.
In addition, our IT systems automatically collect data when you visit our website. This is mainly technical data (e.g., browser, operating system, or the time you accessed the page). This data is collected automatically as soon as you access our website.
What do we do with your data?
Some of the data is collected to ensure the smooth functioning of our website. Other data may be used to analyse your user behaviour.
What are your rights concerning your data?
You have the right to be informed about the origin, recipient, and purpose of the personal data we hold about you at any time free of charge. You also have a right to request the rectification, restriction, or erasure of this data. If you have any questions on this or any other privacy-related topics, contact us any time at the address provided in the legal notice. You also have the right to lodge a complaint with the relevant supervisory authority.
Analytical tools and third-party tools
2. General notes and required information
Please note that data transmission via the internet (e.g., when communicating by email) is always susceptible to security flaws. There is no way to guarantee absolute protection against access by third parties.
Information about the data controller
The entity responsible for data processing on this website is:
Spirit Link GmbH
Allee am Röthelheimpark 41
Telephone: +49 (0) 91 31 / 97 792-0
The data controller is the natural or legal entity that determines the purposes and means of processing personal data (e.g., names, email addresses, etc.), either alone or jointly with others.
Your right to withdraw your consent to data processing
Many data processing operations can only be conducted with your explicit consent. You can withdraw any consent that you have previously given at any time by sending us an email. Any data processing prior to withdrawal of consent remains lawful.
Your right to lodge a complaint with the relevant supervisory authority
In case of privacy violations, the data subject has the right to lodge a complaint with the relevant supervisory authority. The relevant supervisory authority for privacy issues is the regional commissioner of the Federal State where our company is headquartered. For a list of data protection commissioners and their contact information, please refer to the following link: https://www.bfdi.bund.de/DE/Infothek/Anschriften_Links/anschriften_links-node.html.
Your right to data portability
You have the right to receive data that we automatically process based on your consent or in order to perform a contract in a standard, machine-readable format, transmitted either to yourself or to a third party. Any request that the data be transmitted directly to a third person will only be met to the extent that is technically feasible.
SSL or TLS encryption
This site uses SSL or TLS encryption for security reasons and to protect the transmission of sensitive content, such as orders or requests you send to us as the website operators. You can identify that a connection is encrypted by the fact that the browser’s address bar will change from “http://” to “https://” and by the lock icon in your browser bar.
When SSL or TLS encryption is enabled, the data you submit to us cannot be read by others.
Information, restriction, erasure
Under the applicable legal provisions, you have the right to be informed free of charge and at any time about the personal data we hold about you, its origin and recipient as well as the purpose of data processing, and if applicable, you have the right to rectification, restriction, or erasure of such data. For further information about personal data, please contact us any time at the address given in the legal notice.
Objection to promotional emails
We hereby object to use of our data, which is published in the legal notice in compliance with our legal obligations, to send us any unsolicited advertisements and promotional materials. The website operators expressly reserve the right to take legal steps against any unsolicited promotional information, such as spam emails.
3. Data protection officer
Legally mandated data protection officer
Spirit Link GmbH
Allee am Röthelheimpark 41
Telephone: +49 (0) 91 31 / 97 792-0
4. Data collection on our website
Most of the cookies we use are so-called “session cookies” that are automatically deleted after your visit. Other cookies remain stored on your device until you delete them. These cookies enable us to recognize your browser on your next visit to our site.
You can set your browser to automatically notify you of any cookies that are stored, to only allow cookies on a case-by-case basis, to block cookies either for specific sites or generally, or to activate the automatic deletion of cookies when you close your browser. Disabling cookies may impair the functionality of this website.
Server log files
The website provider automatically collects and stores information in so-called server log files that your browser sends to us automatically. This information includes:
- Browser type and version
- Operating system used
- Referrer URL
- Host name of the accessing computer
- Time of the server request
- IP address
This data will not be combined with any other data sources.
Data is processed in accordance with art. 6 par. 1 lit. f GDPR. This allows processing of data for the performance of a contract or in order to take steps prior to entering into a contract.
If you make an enquiry using our contact form, your contact and any other data entered here will be stored for the purpose of processing your enquiry and for any follow up. We will not share this data without your consent.
The data provided via the contact form will thus be processed solely based on your consent (art. 6 par. 1 lit. a GDPR). You can withdraw this consent at any time by sending us an email. Any data processing prior to withdrawal of consent remains lawful.
We will hold the data you enter into the contact form until you request its erasure, withdraw your consent to its storage, or when the purpose for storing the data ceases to apply (e.g., after your enquiry has been processed and closed). Any mandatory legal provisions – in particular legal retention periods – remain unaffected.
5. Analysis tools and advertising
Scope of processing
We use Matomo to analyze the behavior of website visitors, to identify potential threats, “Not Found” pages, or search engine indexing issues, or to find out what content is most popular. Once the data is processed (e.g., number of visitors hitting a “Not Found” page, those viewing only a single page, etc.), Matomo generates reports based on which Spirit Link can take actions, such as changing the layout of pages, publishing new content, etc. If you call up individual pages on our website, the following data is processed: IP address, custom dimensions, user location, date and time, title of the page viewed, URL of the page viewed, URL of the page viewed before the current page, screen resolution, time in local time zone, country, region, city, main browser language, browser product and version information (user agent), session record, mouse events (movements, content forms and clicks) and form interactions.
Purpose and legal basis
The processing of the above-mentioned personal data serves the purpose of analyzing the usage behavior and habits of our users so that we can further develop the website and increase its attractiveness, in particular the findability of interesting content and user-friendliness. Our legitimate interest in processing the data lies in these purposes.
Duration of storage and disclosure
Personal data is not stored because of the immediate anonymization (see above). Matomo is operated exclusively on our own servers, so no data is transmitted to third parties.
6. Plug-ins and tools
Our site uses plug-ins by the video portal Vimeo. The provider is Vimeo Inc., 555 West 18th Street, New York, New York 10011, United States.
When you visit any of our sites that is equipped with a Vimeo plug-in, a connection to Vimeo’s servers will be established. The Vimeo server will be notified as to which of our pages you have visited. In addition, Vimeo will obtain your IP address. This applies even if you are not logged in at Vimeo or don’t have a Vimeo account. The information collected by Vimeo is transmitted to Vimeo’s server in the United States.
If you are logged into your Vimeo account, Vimeo will be able to associate your browsing behaviour directly with your personal profile. You can prevent this by logging out of your Vimeo account.
7. Online Presence on Social Media
We maintain an online presence on social networks and platforms to communicate with current and prospective customers as well as users to inform them about our services.
Please note that in this context, user data may be processed outside of the European Union. This may pose certain risks to users; for instance, user rights might be more difficult to enforce. Please note that US providers that are certified under the Privacy Shield are committed to complying with EU data protection standards.
In addition, user data is normally processed for market research and promotional purposes. For example, platforms can create user profiles based on use patterns and the user’s interests that are derived from these patterns. These profiles can be used to place advertisements on and outside these platforms in accordance with the presumed interests of users. For these purposes, cookies containing use patterns and user interests are typically stored on the computers of users. In addition, use profiles may also store data unrelated to the devices of users (in particular if the users are registered users of these platforms and logged in).
Processing of personal user data is based on our legitimate interest in providing effective information and in communicating with users in accordance with art. 6 par. 1 lit. f GDPR. If the platform providers ask users to consent to the data processing described above, it will be based on art. 6 Abs. 1 lit. a., art. 7 GDPR.
For a detailed description of the various forms of processing and available opt-outs, please refer to the links to the various providers given below.
Please note that the most effective way to make information requests or to assert your user rights is to contact the providers directly. The provider is the only party that has access to a user’s data and therefore take direct action and provide information. If you still require help, please contact us.
If you wish to receive the newsletter offered on the website, we require an email address from you as well as information that allows us to verify that you are the owner of the email address provided and that you agree to receive the newsletter. Further data will not be collected or will only be collected on a voluntary basis. We use these data exclusively for the dispatch of the requested information and do not pass these on to third parties.
The data entered in the newsletter registration form will be processed exclusively on the basis of your consent (Art. 6 para. 1 lit. a DSGVO). You can revoke your consent to the storage of data, email address, and their use to send the newsletter at any time, for example via the “Unsubscribe” link in the newsletter. The legality of the data processing operations that have already taken place remains unaffected by the revocation.
The data you have stored with us for the purpose of subscribing to the newsletter will be stored by us until you unsubscribe from the newsletter and deleted after you cancel the newsletter. This does not affect data stored by us for other purposes (e.g., email addresses for the member area).
This website uses CleverReach to send newsletters. The provider is CleverReach GmbH & Co. KG, Mühlenstr. 43, 26180 Rastede. CleverReach is a service with which the newsletter dispatch can be organised and analysed. The data you enter for the purpose of receiving the newsletter (e.g., email address) is stored on the CleverReach servers in Germany and Ireland.
Our newsletters sent with CleverReach enable us to analyse the behaviour of newsletter recipients. Among other things, it can be analysed how many recipients have opened the newsletter message and how often which link was clicked in the newsletter. With the help of so-called conversion tracking, it can also be analysed whether a predefined action (e.g., purchase of a product on our website) has taken place after clicking on the link in the newsletter. Further information on data analysis through the CleverReach newsletter can be found at: https://www.cleverreach.com/de/funktionen/reporting-und-tracking/.
Data processing is based on your consent (Art. 6 para. 1 lit. a DSGVO). You can revoke this consent at any time by unsubscribing from the newsletter. The legality of the data processing operations that have already taken place remains unaffected by the revocation.
If you do not want an analysis by CleverReach, you must unsubscribe from the newsletter. For this purpose, we provide a corresponding link in every newsletter message. You can also unsubscribe directly on the website.
The data you provide us with for the purpose of subscribing to the newsletter will be stored by us until you unsubscribe from the newsletter and will be deleted both from our servers and from CleverReach’s servers after you cancel the newsletter. Data stored by us for other purposes remain unaffected.
For further details, please refer to CleverReach’s data protection regulations at: https://www.cleverreach.com/de/datenschutz/.
Conclusion of a contract for order processing
We have concluded an order processing agreement with CleverReach and fully implement the strict requirements of the German data protection authorities when using CleverReach.