Privacy policy

Privacy policy

We are very pleased about your interest in our company. Data protection is a particularly high priority for the management of Spesenfuchs GmbH. The internet pages of Spesenfuchs GmbH can generally be used without providing any personal data. However, if a data subject wishes to use special services of our company via our website, processing of personal data could become necessary. If the processing of personal data is necessary and there is no legal basis for such processing, we generally obtain the consent of the data subject.

The processing of personal data, such as the name, address, email address or telephone number of a data subject, is always carried out in accordance with the General Data Protection Regulation and in line with the country-specific data protection regulations applicable to Spesenfuchs GmbH. With this privacy policy, our company would like to inform the public about the type, scope and purpose of the personal data we collect, use and process. Furthermore, data subjects are informed of their rights by means of this privacy policy.

As the controller, Spesenfuchs GmbH has implemented numerous technical and organisational measures to ensure the most complete protection possible of the personal data processed via this website. Nevertheless, internet-based data transmissions can in principle have security gaps, so that absolute protection cannot be guaranteed. For this reason, every data subject is free to transmit personal data to us by alternative means, for example by telephone.

1. Definitions
The privacy policy of Spesenfuchs GmbH is based on the terms used by the European legislator when adopting the General Data Protection Regulation (GDPR). Our privacy policy should be easy to read and understand for the public as well as for our customers and business partners. To ensure this, we would like to explain the terms used in advance.

In this privacy policy we use, among others, the following terms:

Personal data
Personal data means any information relating to an identified or identifiable natural person (hereinafter “data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Data subject
A data subject is any identified or identifiable natural person whose personal data is processed by the controller.

Processing
Processing means any operation or set of operations which is performed on personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Restriction of processing
Restriction of processing means the marking of stored personal data with the aim of limiting their processing in the future.

Profiling
Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

Pseudonymisation
Pseudonymisation means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

Controller or controller responsible for the processing
The controller or controller responsible for the processing is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data. Where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

Processor
A processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

Recipient
A recipient is a natural or legal person, public authority, agency or another body to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law are not regarded as recipients.

Third party
A third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

Consent
Consent of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

2. Name and address of the controller
The controller within the meaning of the General Data Protection Regulation, other data protection laws applicable in the member states of the European Union and other provisions of a data protection nature is:

Spesenfuchs GmbH
Kettengasse 7c
79206 Breisach am Rhein
Germany
Email: info@spesenfuchs.de
Website: https://www.spesenfuchs.de

3. Cookies

You can see which cookies we use and for what purpose in the privacy settings. There you can change or withdraw your consent at any time. You will also find the link in the footer of every page.

4. Collection of general data and information
The website of Spesenfuchs GmbH collects a series of general data and information each time the website is accessed by a data subject or an automated system. This general data and information is stored in the server log files. The following can be recorded: (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrer), (4) the sub-pages accessed via an accessing system on our website, (5) the date and time of access to the website, (6) an internet protocol address (IP address), (7) the internet service provider of the accessing system and (8) other similar data and information that serve to avert danger in the event of attacks on our information technology systems.

When using this general data and information, Spesenfuchs GmbH does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our website correctly, (2) optimise the content of our website and the advertising for it, (3) ensure the long-term functionality of our information technology systems and the technology of our website, and (4) provide law enforcement authorities with the information necessary for prosecution in the event of a cyber attack. Spesenfuchs GmbH therefore analyses this anonymously collected data and information statistically and with the aim of increasing data protection and data security in our company, in order ultimately to ensure an optimal level of protection for the personal data we process. The anonymous data in the server log files is stored separately from all personal data provided by a data subject.

API documentation (api.spesenfuchs.de)
When you access our API documentation, we process the data listed under “server log files”. We deliver all files of the documentation (fonts, program libraries) from our own server; no data is transferred to third parties and no cookies are set. Your choice of language and display mode (light/dark) is stored locally by your browser in “Local Storage”; this information remains on your device and is not transmitted to us. You can delete it in your browser settings. Via the “For AI” menu, you can open the documentation in ChatGPT (OpenAI) or Claude (Anthropic); only the address of the documentation together with a pre-written request to read it is passed on, and the privacy policies of these providers apply.

5. Routine erasure and blocking of personal data
The controller processes and stores personal data of the data subject only for the period necessary to achieve the purpose of storage or insofar as this is provided for by the European legislator or another legislator in laws or regulations to which the controller is subject.

If the purpose of storage no longer applies or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data will be routinely blocked or erased in accordance with the statutory provisions.

6. Rights of the data subject

Right to confirmation
Every data subject has the right granted by the European legislator to obtain confirmation from the controller as to whether personal data concerning him or her are being processed. If a data subject wishes to exercise this right to confirmation, he or she may contact an employee of the controller at any time.

Right of access
Every data subject affected by the processing of personal data has the right granted by the European legislator to obtain from the controller, at any time and free of charge, information about the personal data stored about him or her and a copy of this information. Furthermore, the European legislator has granted the data subject access to the following information:

• the purposes of the processing
• the categories of personal data being processed
• the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations
• where possible, the envisaged period for which the personal data will be stored or, if this is not possible, the criteria used to determine that period
• the existence of the right to request rectification or erasure of personal data concerning him or her, restriction of processing by the controller, or to object to such processing
• the existence of the right to lodge a complaint with a supervisory authority
• where the personal data are not collected from the data subject: any available information as to their source
• the existence of automated decision-making, including profiling, referred to in Article 22 (1) and (4) GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject

The data subject also has the right to know whether personal data have been transferred to a third country or to an international organisation. If this is the case, the data subject also has the right to be informed of the appropriate safeguards relating to the transfer.

If a data subject wishes to exercise this right of access, he or she may contact an employee of the controller at any time.

Right to rectification
Every data subject affected by the processing of personal data has the right granted by the European legislator to obtain the rectification of inaccurate personal data concerning him or her without undue delay. Taking into account the purposes of the processing, the data subject also has the right to have incomplete personal data completed, including by means of a supplementary statement.

If a data subject wishes to exercise this right to rectification, he or she may contact an employee of the controller at any time.

Right to erasure (right to be forgotten)
Every data subject affected by the processing of personal data has the right granted by the European legislator to obtain from the controller the erasure of personal data concerning him or her without undue delay where one of the following grounds applies and insofar as the processing is not necessary:

• The personal data were collected or otherwise processed for purposes for which they are no longer necessary.
• The data subject withdraws the consent on which the processing was based pursuant to Art. 6 (1) (a) GDPR or Art. 9 (2) (a) GDPR, and there is no other legal ground for the processing.
• The data subject objects to the processing pursuant to Art. 21 (1) GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Art. 21 (2) GDPR.
• The personal data have been unlawfully processed.
• The personal data must be erased to comply with a legal obligation under Union or Member State law to which the controller is subject.
• The personal data were collected in relation to the offer of information society services referred to in Art. 8 (1) GDPR.

If one of the above grounds applies and a data subject wishes to request the erasure of personal data stored by Spesenfuchs GmbH, he or she may contact an employee of the controller at any time. The employee of Spesenfuchs GmbH will arrange for the erasure request to be complied with immediately.

If Spesenfuchs GmbH has made the personal data public and our company, as the controller, is obliged to erase the personal data pursuant to Art. 17 (1) GDPR, Spesenfuchs GmbH, taking account of the available technology and the cost of implementation, will take reasonable steps, including technical measures, to inform other controllers processing the published personal data that the data subject has requested the erasure by these other controllers of any links to, or copies or replications of, those personal data, insofar as the processing is not necessary. The employee of Spesenfuchs GmbH will arrange the necessary in each individual case.

Right to restriction of processing
Every data subject affected by the processing of personal data has the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:

• The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
• The processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead.
• The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims.
• The data subject has objected to processing pursuant to Art. 21 (1) GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.

If one of the above conditions is met and a data subject wishes to request the restriction of personal data stored by Spesenfuchs GmbH, he or she may contact an employee of the controller at any time. The employee of Spesenfuchs GmbH will arrange the restriction of processing.

Right to data portability
Every data subject affected by the processing of personal data has the right granted by the European legislator to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format. He or she also has the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where the processing is based on consent pursuant to Art. 6 (1) (a) GDPR or Art. 9 (2) (a) GDPR or on a contract pursuant to Art. 6 (1) (b) GDPR and the processing is carried out by automated means, unless the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

Furthermore, in exercising his or her right to data portability pursuant to Art. 20 (1) GDPR, the data subject has the right to have the personal data transmitted directly from one controller to another, where technically feasible and provided that this does not adversely affect the rights and freedoms of others.

To assert the right to data portability, the data subject may contact an employee of Spesenfuchs GmbH at any time.

Right to object
Every data subject affected by the processing of personal data has the right granted by the European legislator to object at any time, on grounds relating to his or her particular situation, to processing of personal data concerning him or her which is based on Art. 6 (1) (e) or (f) GDPR. This also applies to profiling based on these provisions.

In the event of an objection, Spesenfuchs GmbH will no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or the processing serves the establishment, exercise or defence of legal claims.

If Spesenfuchs GmbH processes personal data for direct marketing purposes, the data subject has the right to object at any time to the processing of personal data for such marketing. This also applies to profiling insofar as it is related to such direct marketing. If the data subject objects to Spesenfuchs GmbH processing for direct marketing purposes, Spesenfuchs GmbH will no longer process the personal data for these purposes.

In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her carried out by Spesenfuchs GmbH for scientific or historical research purposes or for statistical purposes pursuant to Art. 89 (1) GDPR, unless such processing is necessary for the performance of a task carried out in the public interest.

To exercise the right to object, the data subject may contact any employee of Spesenfuchs GmbH directly. In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, the data subject is also free to exercise his or her right to object by automated means using technical specifications.

Automated individual decision-making, including profiling
Every data subject affected by the processing of personal data has the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her, unless the decision (1) is not necessary for entering into, or the performance of, a contract between the data subject and the controller, or (2) is authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, or (3) is based on the data subject’s explicit consent.

If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and the controller, or (2) is based on the data subject’s explicit consent, Spesenfuchs GmbH will implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and to contest the decision.

If the data subject wishes to exercise rights relating to automated decisions, he or she may contact an employee of the controller at any time.

Right to withdraw consent under data protection law
Every data subject affected by the processing of personal data has the right granted by the European legislator to withdraw consent to the processing of personal data at any time.

If the data subject wishes to exercise the right to withdraw consent, he or she may contact an employee of the controller at any time.

7. Data protection provisions on the use of Google Analytics (with anonymisation function)
The controller has integrated the Google Analytics component (with anonymisation function) on this website. Google Analytics is a web analytics service. Web analytics is the collection, gathering and evaluation of data about the behaviour of visitors to websites. A web analytics service collects, among other things, data on the website from which a data subject came to a website (so-called referrer), which sub-pages of the website were accessed, or how often and for how long a sub-page was viewed. Web analytics is mainly used to optimise a website and for the cost-benefit analysis of internet advertising.

The operating company of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.

For web analytics via Google Analytics, the controller uses the addition “_gat._anonymizeIp”. By means of this addition, the IP address of the data subject’s internet connection is shortened and anonymised by Google if access to our website takes place from a member state of the European Union or from another state party to the Agreement on the European Economic Area.

The purpose of the Google Analytics component is to analyse visitor flows on our website. Google uses the data and information obtained, among other things, to evaluate the use of our website, to compile online reports for us showing the activities on our website, and to provide further services related to the use of our website.

Google Analytics sets a cookie on the data subject’s information technology system. What cookies are has already been explained above. By setting the cookie, Google is enabled to analyse the use of our website. Each time one of the individual pages of this website operated by the controller and on which a Google Analytics component has been integrated is accessed, the internet browser on the data subject’s information technology system is automatically prompted by the respective Google Analytics component to transmit data to Google for the purpose of online analysis. As part of this technical procedure, Google obtains knowledge of personal data, such as the IP address of the data subject, which Google uses, among other things, to trace the origin of visitors and clicks and subsequently to enable commission settlements.

The cookie is used to store personal information, such as the time of access, the location from which access was made and the frequency of visits to our website by the data subject. Each time our website is visited, this personal data, including the IP address of the internet connection used by the data subject, is transmitted to Google in the United States of America. This personal data is stored by Google in the United States of America. Google may pass on this personal data collected through the technical procedure to third parties.

As already described above, the data subject can prevent our website from setting cookies at any time by means of a corresponding setting in the internet browser used and thus permanently object to the setting of cookies. Such a setting of the internet browser used would also prevent Google from setting a cookie on the data subject’s information technology system. In addition, a cookie already set by Google Analytics can be deleted at any time via the internet browser or other software programs.

Furthermore, the data subject has the option of objecting to and preventing the collection of data generated by Google Analytics relating to the use of this website and the processing of this data by Google. To do this, the data subject must download and install a browser add-on from https://tools.google.com/dlpage/gaoptout. This browser add-on tells Google Analytics via JavaScript that no data and information about visits to websites may be transmitted to Google Analytics. Google regards the installation of the browser add-on as an objection. If the data subject’s information technology system is later deleted, formatted or reinstalled, the data subject must reinstall the browser add-on in order to deactivate Google Analytics. If the browser add-on is uninstalled or deactivated by the data subject or another person within their sphere of control, it can be reinstalled or reactivated.

Further information and Google’s applicable privacy policy can be found at https://www.google.de/intl/de/policies/privacy/ and http://www.google.com/analytics/terms/de.html. Google Analytics is explained in more detail at https://www.google.com/intl/de_de/analytics/.

8. Legal basis for the processing
Art. 6 (1) (a) GDPR serves as the legal basis for our company for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, with processing operations necessary for the delivery of goods or the provision of any other service or consideration, the processing is based on Art. 6 (1) (b) GDPR. The same applies to processing operations necessary to carry out pre-contractual measures, for example in the case of enquiries about our products or services. If our company is subject to a legal obligation which requires the processing of personal data, for example to fulfil tax obligations, the processing is based on Art. 6 (1) (c) GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if a visitor were injured on our premises and his or her name, age, health insurance data or other vital information had to be passed on to a doctor, hospital or other third party. The processing would then be based on Art. 6 (1) (d) GDPR. Finally, processing operations could be based on Art. 6 (1) (f) GDPR. Processing operations not covered by any of the above legal bases are based on this legal basis if the processing is necessary to safeguard a legitimate interest of our company or of a third party, provided that the interests, fundamental rights and freedoms of the data subject do not prevail. We are permitted to carry out such processing operations in particular because they have been specifically mentioned by the European legislator. In this respect, the legislator took the view that a legitimate interest could be assumed if the data subject is a customer of the controller (Recital 47 sentence 2 GDPR).

9. Legitimate interests pursued by the controller or a third party
Where the processing of personal data is based on Article 6 (1) (f) GDPR, our legitimate interest is to carry out our business for the benefit of the well-being of all our employees and our shareholders.

10. Period for which the personal data will be stored
The criterion for the period of storage of personal data is the respective statutory retention period. After expiry of this period, the corresponding data is routinely erased, provided that it is no longer required for the performance or initiation of a contract.

11. Statutory or contractual requirements to provide the personal data; necessity for the conclusion of a contract; obligation of the data subject to provide the personal data; possible consequences of failure to provide them
We would like to inform you that the provision of personal data is partly required by law (e.g. tax regulations) or may also result from contractual provisions (e.g. information on the contractual partner). Sometimes it may be necessary for the conclusion of a contract that a data subject provides us with personal data which must subsequently be processed by us. For example, the data subject is obliged to provide us with personal data if our company concludes a contract with him or her. Failure to provide the personal data would mean that the contract with the data subject could not be concluded. Before providing personal data, the data subject must contact one of our employees. Our employee will explain to the data subject on a case-by-case basis whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and what the consequences of failure to provide the personal data would be.

12. Existence of automated decision-making
As a responsible company, we do not use automated decision-making or profiling.