Privacy policy for the Spreadly website

I. General information

Spreadly GmbH, Forstenrieder Weg 1G, 82065 Baierbrunn, operator of the website spreadly.app, attaches great importance to the protection of the personal data of the users of the website. We would therefore like to inform you in detail below about what data we collect from you when you visit our website and use our offers there, how we process or use this data in the following and what rights you are entitled to in this respect.

Your personal data will only be processed by us on the basis of statutory data protection law, i.e. the EU General Data Protection Regulation (GDPR), the German Federal Data Protection Act (BDSG-neu) and the German Telemedia Act (TMG).

The scope of the data collected and processed by us differs depending on whether you only visit our website to retrieve information or also make use of services offered by us via our website.

A lista dos nossos subprocessadores quando utilizas o Spreadly como equipa ou empresa pode ser consultada aqui: https://spreadly.app/pt/legal/privacy/sub-processors

II. Responsible party

The controller within the meaning of the General Data Protection Regulation and other data protection regulations is

Spreadly GmbH
Forstenrieder Weg 1G
82065 Baierbrunn
Alemanha

Represented by the management board: Florian Theimer

Email: info@spreadly.app

III. Definitions

Our privacy policy uses the terms of the EU General Data Protection Regulation (GDPR), which we would like to briefly explain for you for easier understanding. These and other definitions can be found in Art. 4 GDPR.

1. 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.

2. Data subject

"data subject" means any identified or identifiable natural person whose personal data are processed by the controller.

3. Processing

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

4. Restriction of processing

"Restriction of processing" means the marking of stored personal data with the aim of restricting its future processing.

5. Pseudonymization

"Pseudonymization" 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 organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

6. Controller

"Controller" means 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.

7. Processor

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

8. Recipient

"Recipient" means 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 shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.

9. Third party

"Third party" means 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 authorized to process personal data.

10. Constent

"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.

IV. General information on data processing

1. Categories of personal data

We process the following categories of personal data:

  • Inventory data (e.g. names, addresses, functions, organizational affiliation, etc.);
  • Contact data (e.g. e-mail, telephone/fax numbers, etc.);
  • Content data (e.g. text entries, image files, videos, etc.);
  • Usage data (e.g. access data);
  • Meta/communication data (e.g. IP addresses).

2. Recipients or categories of recipients of personal data

If we disclose data to other persons and companies such as web hosts, contract processors or third parties as part of our processing, transfer it to them or otherwise grant them access to the data, this is done on the basis of a legal permission (e.g. if a transfer of the data to third parties pursuant to Art. 6 para. 1 lit. b GDPR is necessary for the fulfillment of the contract), if the data subjects have consented or if a legal obligation provides for this.

3. Duration of the storage of personal data

The criterion for the duration of the storage of personal data is the respective statutory retention period. After this period has expired, the corresponding data will be deleted if it is no longer required to achieve the purpose, fulfill the contract or initiate a contract.

4. Transfers to third countries

If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if this occurs in the context of the use of third-party services or disclosure or transfer of data to third parties, this will only take place if it is done to fulfill our (pre-)contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or have the data processed in a third country only if the special requirements of Art. 44 et seq. GDPR, i.e. the processing takes place, for example, on the basis of special guarantees, such as the officially recognized determination of a level of data protection corresponding to the EU or compliance with officially recognized special contractual obligations (so-called "standard contractual clauses").

V. Data processing in the context of visiting our website

1. Log files

Every time a data subject accesses our website, general data and information is stored in the log files of our system:

  • Date and time of the request (timestamp);
  • Request details and destination address (protocol version, HTTP method, referrer, user agent string);
  • Name of the requested file and amount of data transferred (requested URL incl. query string, size in bytes);
  • Message as to whether the request was successful (HTTP status code).

When using this general data and information, we do not draw any conclusions about the data subject. There is no personal evaluation or evaluation of the data for marketing purposes or profiling. The IP address is not stored in this context.

The legal basis for the temporary storage of data is Art. 6 para. 1 lit. f GDPR. The collection of data for the provision of the website and the storage of data in log files is absolutely necessary for the secure operation of our website. Consequently, the data subject has no option to object.

2. Malware detection and log data analysis

We collect log data that is generated during the operation of our company's communication technology and evaluate it automatically, insofar as this is necessary for the detection, limitation or elimination of malfunctions or errors in communication technology or the defense against attacks on our information technology or the detection and defense against malware.

The legal basis for the temporary storage and analysis of the data is Art. 6 para. 1 lit. f GDPR. The storage and analysis of the data is absolutely necessary for the provision of the website and for its secure operation. Consequently, the data subject has no option to object.

3. Cookies

Cookies are used on our website. Cookies are small text files that are exchanged between the web browser and the hosting server. Cookies are stored on the user's computer and transmitted by it to our website. In the web browser you are using, you can restrict or prevent the use of cookies by selecting the appropriate settings. Cookies that have already been saved can be deleted at any time. If cookies are deactivated for our website, this may mean that the website cannot be displayed or used to its full extent.

The legal basis for the processing of personal data using cookies is Art. 6 para. 1 lit. f GDPR.

We use the cookie consent tool Cookiebot from the service provider Cybot A/S, 1058 Copenhagen, Denmark to obtain your consent within the meaning of Art. 6 para. 1 sentence 1 lit. a GDPR for the storage of certain cookies in your browser and to document this in accordance with data protection regulations. Saving a cookie is technically necessary for the use of Cookiebot. When you visit our website for the first time, Cookiebot is displayed as a pop-up window in which you can activate certain functional groups of cookies. This data is stored, but not passed on to the service provider.

The cookie settings you have made and the data collected will be stored until you ask us to delete them or delete the Cookiebot cookie yourself or until the purpose for data storage no longer applies. Mandatory statutory retention periods remain unaffected.

You can find more information about Cookiebot at https://www.cookiebot.com/de/privacy-policy/.

4. Hosting

The hosting services we use serve to provide the following services: Infrastructure and platform services, computing capacity, storage space and database services, security services and technical maintenance services that we use for the purpose of operating our website.

In doing so, we or our processor process inventory data, contact data, content data, contract data, usage data, meta and communication data of users of our website on the basis of our legitimate interests in the efficient and secure provision of this online offer in accordance with Art. 6 para. 1 lit. f GDPR in conjunction with Art. 28 GDPR (conclusion of a contract for order processing).

5. Social media

We do not use social media plugins on our website, but so-called social bookmarks (these are integrated as links to the corresponding services. If the integrated graphic is clicked on by the user, the user is redirected to the page of the respective provider). We would like to point out that, as the provider of our website, we have no knowledge of the data transmitted to and used by the respective social media channel.

6. Hubspot

This website uses HubSpot, an integrated software solution.

Pseudonymous user profiles can be created from the processed data. We only use Hubspot with activated IP anonymization. This means that the IP address of users is shortened by Hubspot within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Hubspot server in the USA and truncated there. The IP address transmitted by the user's browser is not merged with other Hubspot data. Users can prevent the storage of cookies by setting their browser software accordingly.

The legal basis for the processing of personal data is Art. 6 para. 1 lit. b or lit. f GDPR.

HubSpot is a software company from the USA. To legitimize the transfer of data to the USA, HubSpot Inc. relies on EU standard contractual clauses: https://legal.hubspot.com/dpa

Further information on data protection can be found in HubSpot's privacy policy:

7. Use of Plausible

We use the web analysis tool Plausible Analytics from the service provider OÜ Plausible Insights, Västriku tn 2, Tartu 50403, Estonia. Plausible Analytics does not set any cookies and does not store any information in the browser. In general, Plausible Analytics does not collect any personal data. Further information about Plausible Analytics and its privacy policy can be found at the following web address: https://plausible.io/.

8. Use of Cloudflare

We use the "Cloudflare" service of the service provider Cloudflare Inc, 101 Townsend St., San Francisco, CA 94107, USA (hereinafter referred to as "Cloudflare"). This is a service that is used in particular to deliver large files (such as graphics, page content or scripts) through a network of regionally distributed servers connected via the Internet. The use of Cloudflare's Content Delivery Network helps, for example, to optimize the loading speed of this website.

The use of Cloudflare is based on our legitimate interest in providing our website as error-free and secure as possible (Art. 6 para. 1 lit. f GDPR).

Cloudflare, based in the USA, is certified for the "Privacy Shield", which guarantees compliance with the level of data protection applicable in the EU. In addition, we have concluded a data processing agreement (DPA) with Cloudflare to comply with the provisions of the GDPR.

The specific storage period of the processed data cannot be influenced by us, but is determined by Cloudflare, Inc. Further information on security and data protection at Cloudflare can be found here: https://www.cloudflare.com/privacypolicy/.

9. payment service provider

Use of Stripe

We offer the option of processing the payment transaction via the payment service provider Stripe, ℅ Legal Process, 510 Townsend St., San Francisco, CA 94103 (Stripe). This corresponds to our legitimate interest in offering an efficient and secure payment method (Art. 6 para. 1 lit. f GDPR). In this context, we pass on the following data to Stripe insofar as it is necessary for the fulfillment of the contract (Art. 6 para. 1 lit. b. GDPR):

  • name of the cardholder
  • e-mail address
  • customer number
  • invoice number
  • bank details
  • credit card details
  • credit card expiry date
  • credit card verification number (CVC)
  • date and time of the transaction
  • transaction number
  • name of the provider
  • location
  • PayPal e-mail address
  • billing address

The processing of the data specified in this section is neither legally nor contractually required. Without the transmission of your personal data, we cannot process a payment via Stripe. You have the option of choosing a different payment method.

Stripe assumes a dual role as controller and processor for data processing activities. As the controller, Stripe uses your transmitted data to fulfill regulatory obligations. This corresponds to Stripe's legitimate interest (pursuant to Art. 6 para. 1 lit. f GDPR) and serves the performance of the contract (pursuant to Art. 6 para. 1 lit. b GDPR). We have no influence on this process.

Stripe acts as a processor in order to complete transactions within the payment networks. Within the scope of the order processing relationship, Stripe acts exclusively in accordance with our instructions and has been contractually obliged to comply with the data protection regulations within the meaning of Art. 28 GDPR.

Stripe has implemented compliance measures for international data transfers. These apply to all global activities where Stripe processes personal data of natural persons in the EU. These measures are based on the EU Standard Contractual Clauses (SCCs).

You can find further information on objection and removal options vis-à-vis Stripe at: https://stripe.com/privacy-center/legal.

Your data will be stored by us until payment processing has been completed. This also includes the period required for the processing of refunds, receivables management and fraud prevention. A statutory retention period of 10 years applies to us in accordance with Section 257 of the German Commercial Code (HGB).

10. Use of Sentry

To improve the technical stability of our website by monitoring system stability and detecting code errors, we use the Sentry service provided by Sentry, 1501 Mariposa St #408, San Francisco, CA 94107, USA. This application is used solely for the above-mentioned purposes and does not evaluate any personal data for advertising purposes. User data, such as information about the device or time of error, is collected anonymously. Further information on this can be found in Sentry's privacy policy: https://sentry.io/privacy/.

11. Use of SalesViewer®

This website uses SalesViewer® technology from SalesViewer® GmbH to collect and store data for marketing, market research and optimization purposes on the basis of the website operator's legitimate interests (Art. 6 (1) (f) GDPR). For this purpose, a javascript-based code is used to collect company-related data and the corresponding use. The data collected using this technology is encrypted using a non-reversible one-way function (known as hashing). The data is immediately pseudonymized and is not used to personally identify the visitor to this website.

The data stored in the context of Salesviewer will be deleted as soon as it is no longer required for its intended purpose and the deletion does not conflict with any statutory retention obligations.

You can object to the collection and storage of data at any time with effect for the future by clicking on this link https://www.salesviewer.com/opt-out to prevent the collection by SalesViewer® within this website in the future. An opt-out cookie for this website will be stored on your device. If you delete your cookies in this browser, you must click on this link again.

VI. Data processing in the context of establishing contact

1. Contact by e-mail

You can contact our company by e-mail using the e-mail addresses published on our website.

If you use this contact channel, the data you provide (e.g. surname, first name, address), but at least the e-mail address, as well as the information contained in the e-mail and any personal data you provide will be stored for the purpose of contacting you and processing your request. The following data is also collected by our system:

  • IP address of the accessing computer;
  • date and time of the e-mail.

The legal basis for the processing of personal data in the context of e-mails sent to us is Art. 6 para. 1 lit. b or lit. f GDPR.

2. Contact via website contact form

If you use the contact form provided on our website for communication and questions, it is necessary to provide your e-mail address. Without this data, your request sent via the contact form cannot be processed. Providing your address is optional and enables us to process your request by post if you wish.

In addition, the following data is collected by our system:

  • IP address of the accessing computer;
  • URL of the contact form
  • Date and time of the contact request

The legal basis for the processing of personal data in the context of e-mails sent to us is Art. 6 para. 1 lit. b or lit. f GDPR.

We use the CRM system "HubSpot", from the provider HubSpot, Inc. HubSpot Headquarters (Cambridge, MA) 25 First St., 2nd floor Cambridge, Massachusetts 02141, USA) on the basis of our legitimate interests (efficient and fast processing of user inquiries). For this purpose, we have concluded an order processing contract with HubSpot with so-called standard contractual clauses, in which HubSpot undertakes to process user data only in accordance with our instructions and to comply with the EU data protection level.

3. Contact by letter

If you send us a letter, the data you provide (e.g. surname, first name, address) and the information contained in the letter, together with any personal data you provide, will be stored for the purpose of contacting you and processing your request.

The legal basis for the processing of personal data in the context of letters sent to us is Art. 6 para. 1 lit. b or lit. f GDPR.

VII. Data processing when subscribing to our newsletter

If you subscribe to our newsletter mailing list, your e-mail address and the newsletter you have selected will be stored by us on a server.

In addition, the following data is collected by the system during registration:

  • IP address of the accessing computer;
  • date and time of registration.

Your consent is obtained for the processing of the data as part of the registration process and reference is made to this privacy policy. The data is processed on the basis of your consent in accordance with Art. 6 para. 1 lit. a GDPR and within the scope of the legitimate interest in accordance with Art. 6 para. 1 lit. f GDPR.

We use this data exclusively for sending the newsletter. The registration system with an additional confirmation message containing a link to the final registration (double opt-in) ensures that the newsletter was requested by you and not by a third party. When you register, your data is stored on our servers and a confirmation message with a link to the final registration is generated and sent to the e-mail address you have provided. Only when you confirm the link in the email will your data for sending the newsletter be stored for the duration of your use of our service.

If you no longer agree to the storage of your data for this purpose and therefore no longer wish to use our services, you can unsubscribe from our newsletter at any time. There is a corresponding link in every newsletter for this purpose. The personal data provided by you for the newsletter subscription will then be deleted.

Unsubscribe from the newsletter

You can unsubscribe from our newsletter at any time.

You will find a link to unsubscribe from the newsletter at the end of each newsletter.

The legal basis for the processing of personal data in the context of sending the newsletter is Art. 6 para. 1 lit. a GDPR.

VIII. Your rights

As a data subject, you have the following rights in connection with the processing of your personal data:

1. Right to information

(1) The data subject shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information:

a) the purposes of the processing;

b) the categories of personal data that are processed;

c) 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 organizations;

d) where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;

e) the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;

f) the existence of a right of appeal to a supervisory authority;

(g) where the personal data are not collected from the data subject, any available information as to their source;

h) the existence of automated decision-making, including profiling, referred to in Art. 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.

(2) Where personal data are transferred to a third country or to an international organization, the data subject shall have the right to be informed of the appropriate safeguards pursuant to Article 46 GDPR relating to the transfer.

2. Right to rectification

The data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

3. Right to erasure

(1) The data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies:

a) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed

b) The data subject withdraws consent on which the processing is based according to point (a) of Article 6(1), or point (a) of Article 9(2) GDPR, and where there is no other legal ground for the processing.

c) 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.

d) The personal data was processed unlawfully.

e) The deletion of personal data is necessary to fulfill a legal obligation under Union law or the law of the Member States to which the controller is subject.

f) The personal data was collected in relation to information society services offered in accordance with Art. 8 para. 1 GDPR.

(2) Where the controller has made the personal data public and is obliged pursuant to paragraph 1 to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, those personal data.

(3) Paragraphs 1 and 2 shall not apply if the processing is necessary

a) to exercise the right to freedom of expression and information;

b) for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;

c) for reasons of public interest in the area of public health in accordance with Art. 9 para. 2 lit. h) and i) and Art. 9 para. 3 GDPR;

d) for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) in so far as the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing; or

e) for the assertion, exercise or defense of legal claims.

4. Right to restriction of processing

(1) The data subject shall have the right to obtain from the controller restriction of processing where one of the following applies:

a) 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,

b) the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;

c) 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 defense of legal claims, or

d) 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.

(2. Where processing has been restricted pursuant to paragraph 1, such personal data shall, with the exception of storage, only be processed with the data subject's consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.

5. Right to data portability

(1) The data subject shall have the right 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 and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where

a) the processing is based on consent pursuant to Art. 6 para. 1 lit. a) or Art. 9 para. 2 lit. a) GDPR or on a contract pursuant to Art. 6 para. 1 lit. b) GDPR and

b) the processing is carried out by automated means.

(2) In exercising his or her right to data portability pursuant to paragraph 1, the data subject shall have the right to have the personal data transmitted directly from one controller to another, where technically feasible.

The right referred to in paragraph 1 shall not adversely affect the rights and freedoms of other persons.

This right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

6. Right of objection

The data subject has the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on point (e) or (f) of Article 6(1) GDPR, including profiling based on those provisions. The controller shall no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defense of legal claims.

In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, the data subject may exercise his or her right to object by automated means using technical specifications.

7. Right of withdrawal

The data subject has the right to withdraw their declaration of consent under data protection law at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

8. Right to lodge a complaint with a supervisory authority

Without prejudice to any other administrative or judicial remedy, every data subject shall have the right to lodge a complaint with a supervisory authority, in particular in the Member State of his or her habitual residence, place of work or place of the alleged infringement if the data subject considers that the processing of personal data relating to him or her infringes this Regulation.

IX. Changes to this privacy policy

We reserve the right to amend these data protection provisions at any time with effect for the future. A current version is always available on the website. Please visit the website regularly and inform yourself about the applicable data protection provisions.

Status: February 2024

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