Name and address of the person responsible

The responsible person in terms of the basic data protection regulation and other national data protection laws of the member states and other data protection regulations is the:

Struktur AG
Hauptmannsreute 44A
70192 Stuttgart
Deutschland

Telefon: +49 711/25 24 28-0
E-Mail: info@struktur.de
Website: www.spreed.eu
Vorstand: Niels Mache

Stand: 15.05.2020

General information on data processing

1. Scope of processing of personal data

As a matter of principle, we process personal data of our users only to the extent necessary to provide a functional website and our contents and services. The processing of personal data of our users regularly only takes place with the user's consent. An exception is made in those cases where prior consent cannot be obtained for factual reasons and the processing of the data is permitted by law.

2. Legal basis for the processing of personal data

Insofar as we obtain the consent of the data subject for the processing of personal data, Art. 6 para. 1 lit. a EU Data Protection Basic Regulation (DSGVO) serves as the legal basis. When processing personal data which is necessary for the performance of a contract to which the data subject is a party, Art. 6 para. 1 lit. b DSGVO serves as the legal basis. This also applies to processing operations which are necessary to carry out pre-contractual measures. Insofar as processing of personal data is necessary to fulfil a legal obligation to which our company is subject, Art. 6 para. 1 lit. c DSGVO serves as the legal basis. In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 para. 1 lit. d DSGVO serves as the legal basis. If the processing is necessary to safeguard a legitimate interest of our company or of a third party and if the interests, fundamental rights and freedoms of the data subject do not outweigh the former interest, Article 6 (1) (f) DSGVO serves as the legal basis for the processing.

3. Data erasure and storage period

The personal data of the person concerned will be deleted or blocked as soon as the purpose of the storage no longer applies. Furthermore, data may be stored if this has been provided for by the European or national legislator in EU regulations, laws or other regulations to which the person responsible is subject. Data will also be blocked or deleted when a storage period prescribed by the above-mentioned standards expires, unless there is a need to continue storing the data for the purpose of concluding or fulfilling a contract.

Provision of the website and creation of log files

1. Description and scope of data processing

Whenever our website is called up, our system automatically collects data and information from the computer system of the calling computer. The following data is collected:

Information about the browser type and the version used
The user's operating system
The IP address of the user
Date and time of access
Websites from which the user's system accesses our website
Websites that are called up by the user's system via our website

The data is also stored in the log files of our system. These data are not stored together with other personal data of the user.

2. Legal basis for the data processing

The legal basis for the temporary storage of data and log files is Art. 6 para. 1 lit. f DSGVO.

3. Purpose of data processing

The temporary storage of the IP address by the system is necessary to enable the website to be delivered to the user's computer. For this purpose, the user's IP address must remain stored for the duration of the session.The storage in log files is done to ensure the functionality of the website. In addition, the data serves us to optimize the website and to ensure the security of our information technology systems. An evaluation of the data for marketing purposes does not take place in this context.

These purposes also include our legitimate interest in data processing in accordance with Art. 6 Para. 1 lit. f DSGVO

4. Duration of storage

The data will be deleted as soon as they are no longer necessary for the purpose for which they were collected. In the case of the collection of data for the provision of the website, this is the case when the respective session is ended.In the case of data stored in log files, the data will be deleted after seven days at the latest. Storage beyond this period is possible. In this case, the IP addresses of the users are deleted or alienated so that an assignment of the calling client is no longer possible.

5. Possibility of objection and removal

The collection of data for the provision of the website and the storage of the data in log files is mandatory for the operation of the website. There is therefore no possibility of objection on the part of the user.

Use of cookies

1. Description and scope of data processing

Our website uses cookies. Cookies are text files that are stored in the Internet browser or by the Internet browser on the user's computer system. If a user calls up a website, a cookie may be stored on the user's operating system. This cookie contains a characteristic string of characters that enables the browser to be uniquely identified when the website is called up again.

We use cookies to make our website more user-friendly. Some elements of our website require the calling browser to be able to be identified even after a page change.

The following data is stored and transmitted in the cookies:

Language settings
Log-in information

2. Legal basis for the data processing

The legal basis for the processing of personal data using cookies is Art. 6 para. 1 lit. f DSGVO.
The legal basis for the processing of personal data using cookies for analysis purposes is Art. 6 para. 1 lit. a DSGVO, if the user gives his consent.

3. Purpose of data processing

The purpose of using technically necessary cookies is to simplify the use of websites for users. Some functions of our website cannot be offered without the use of cookies. For these it is necessary that the browser is recognized even after a page change.

Analysis cookies are used to improve the quality of our website and its contents. Through the analysis cookies we learn how a website is used and can thus constantly optimise our offer via the website.
These purposes also include our legitimate interest in the processing of personal data in accordance with Art. 6 para. 1 lit. f DSGVO.

4. Duration of storage, possibility of objection and removal

Cookies are stored on the user's computer and transmitted by the user to our site. Therefore you as a user have full control over the use of cookies. By changing the settings in your Internet browser, you can deactivate or restrict the transmission of cookies. Already stored cookies can be deleted at any time. This can also be done automatically. If cookies for our website are deactivated, it may not be possible to use all the functions of the website to their full extent.

Registration

1. Description and scope of data processing

On our website we offer users the possibility to register by providing personal data. The data is entered into an input mask, transmitted to us and stored. The data will not be passed on to third parties. The following data is collected during the registration process:

e-mail address
Name
Company
Address, Country
Language
Phone number
Username
Password

During the registration process, the user's consent to the processing of this data is obtained.

2. Legal basis for the data processing

The legal basis for the processing of the data is Art. 6 para. 1 lit. a DSGVO if the user has given his consent.

If the registration serves the fulfilment of a contract to which the user is a party or the implementation of pre-contractual measures, the additional legal basis for the processing of the data is Art. 6 para. 1 letter b DSGVO.

3. Purpose of data processing

User registration is required for the provision of certain contents and services on our website. This enables the user to create, conduct and follow up video conferences independently. He can transmit his screen and interact with the participants (e.g. via chat), hold presentations and collaborate with other participants.

4. Duration of storage

The data will be deleted as soon as they are no longer necessary for the purpose for which they were collected. This is the case for data collected during the registration process for the fulfilment of a contract or for the implementation of pre-contractual measures if the data is no longer necessary for the implementation of the contract. Even after conclusion of the contract, it may still be necessary to store personal data of the contractual partner in order to comply with contractual or legal obligations.

5. Possibility of objection and removal

As a user you have the possibility to cancel the registration at any time.

To do so, click on your profile picture in the top right-hand corner and then select "Settings". A menu appears on the left side, click on "Delete account". In the next step you activate the checkbox and confirm that you really want to delete your account. This action cannot be undone and your user account and settings will be irrevocably deleted.

If the data is required for the fulfilment of a contract or for the implementation of pre-contractual measures, an early deletion of the data is only possible if there are no contractual or legal obligations that prevent a deletion.

Order processing in the online shop and customer account

We process the data of our customers in the context of the order procedures in our online shop, in order to enable them to select and order the selected products and services, as well as their payment and delivery, or execution.

The processed data includes inventory data, communication data, contract data, payment data and the persons affected by the processing include our customers, interested parties and other business partners. The processing is carried out for the purpose of providing contractual services within the operation of an online shop, billing, delivery and customer services.

The processing is based on Art. 6 para. 1 lit. b (execution of order transactions) and c (legally required archiving) DSGVO. The information marked as required is required for the establishment and fulfilment of the contract. We disclose the data to third parties only within the scope of delivery, payment or within the scope of the legal permits and obligations to legal advisors and authorities. The data will only be processed in third countries if this is necessary for the fulfilment of the contract (e.g. on customer request for delivery or payment).

When using our online services, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests, as well as the user's protection against misuse and other unauthorized use. This data will not be passed on to third parties unless it is necessary to pursue our claims or there is a legal obligation to do so in accordance with Art. 6 Para. 1 lit. c DSGVO.

Deletion takes place after the expiry of statutory warranty and comparable obligations, the necessity of storing the data is reviewed every three years; in the case of statutory archiving obligations, deletion takes place after their expiry (end of commercial law (6 years) and tax law (10 years) storage obligation).

Contact form and e-mail contact

1. Description and scope of data processing

On our website there is a contact form which can be used for electronic contact. If a user takes advantage of this possibility, the data entered in the input mask is transmitted to us and stored. These data are: Name, e-mail address and optionally a subject and your message to us.

At the time the message is sent, the following data is also stored:

The IP address of the user
Date and time of the request

For the processing of the data, your consent will be obtained during the sending process and reference will be made to this privacy policy.

Alternatively, it is possible to contact us via the e-mail address provided. In this case, the user's personal data transmitted with the e-mail will be stored.

In this context, the data will not be passed on to third parties. The data will be used exclusively for processing the conversation.

2. Legal basis for the data processing

The legal basis for the processing of the data is Art. 6 para. 1 lit. a DSGVO if the user has given his consent.

The legal basis for the processing of data transmitted in the course of sending an e-mail is Art. 6 para. 1 letter f DSGVO. If the e-mail contact is aimed at the conclusion of a contract, the additional legal basis for processing is Art. 6 para. 1 lit. b DSGVO.

3. Purpose of data processing

The processing of the personal data from the input mask serves us only for the processing of the establishment of contact. In the case of contacting us by e-mail, this is also the necessary legitimate interest in the processing of the data.
The other personal data processed during the sending process serve to prevent misuse of the contact form and to ensure the security of our information technology systems.

4. Duration of storage

The data will be deleted as soon as they are no longer necessary for the purpose for which they were collected. For the personal data from the input mask of the contact form and those sent by e-mail, this is the case when the respective conversation with the user has ended. The conversation is finished when it can be concluded from the circumstances that the matter in question has been finally clarified.

The additional personal data collected during the sending process will be deleted after a period of seven days at the latest.

5. Possibility of objection and removal

The user has the possibility to revoke his consent to the processing of personal data at any time. If the user contacts us by e-mail, he can object to the storage of his personal data at any time. In such a case the conversation cannot be continued. A written declaration of revocation (e.g. by mail, fax, e-mail) is required. All personal data stored in the course of the contact will be deleted in this case.

Data protection information in the application procedure

We process the applicant data only for the purpose and within the scope of the application procedure in accordance with the legal requirements. The applicant data is processed for the purpose of fulfilling our (pre-)contractual obligations within the scope of the application procedure in accordance with Art. 6 Para. 1 lit. b. DSGVO Art. 6 para. 1 lit. f. DSGVO if the data processing becomes necessary for us, e.g. within the framework of legal procedures (in Germany, § 26 BDSG applies additionally).

The application procedure requires that applicants provide us with the applicant data. The necessary applicant data is derived from the job descriptions and basically includes personal details, postal and contact addresses and the documents belonging to the application, such as cover letter, CV and certificates. In addition, applicants can voluntarily provide us with additional information.

By submitting their application to us, applicants agree to the processing of their data for the purposes of the application procedure in accordance with the type and scope described in this data protection declaration.

Insofar as special categories of personal data within the meaning of Art. 9 Para. 1 DSGVO are voluntarily communicated as part of the application procedure, their processing is also carried out in accordance with Art. 9 Para. 2 letter b DSGVO (e.g. health data, such as severely disabled status or ethnic origin). Insofar as special categories of personal data within the meaning of Art. 9 Para. 1 DSGVO are requested from applicants as part of the application procedure, their processing is also carried out in accordance with Art. 9 Para. 2 letter a DSGVO (e.g. health data if this is necessary for the exercise of the profession).

Applicants can send us their applications by e-mail. Please note, however, that e-mails are generally not sent in encrypted form and that the applicants themselves must ensure that they are encrypted. Instead of applying by e-mail, applicants can still send us their application by post.

In the event of a successful application, the data provided by the applicants can be processed by us for the purposes of the employment relationship. Otherwise, if the application for a job offer is not successful, the applicants' data is deleted. Applicants' data is also deleted if an application is withdrawn, which applicants are entitled to do at any time.

Subject to a justified revocation by the applicants, the data will be deleted after a period of six months so that we can answer any follow-up questions regarding the application and meet our obligations to provide evidence under the Equal Treatment Act. Invoices for any reimbursement of travel expenses will be archived in accordance with tax law requirements.

Web analysis by Matomo (formerly PIWIK)

1. Scope of processing of personal data

We use the open source software tool Matomo (formerly PIWIK) on our website to analyse the surfing behaviour of our users. The software sets a cookie on the user's computer (see above for further information on cookies). If individual pages of our website are called up, the following data is stored:

Two bytes of the IP address of the calling system of the user
The accessed website
The website from which the user has reached the accessed website (referrer)
The subpages that are called from the called web page
The time spent on the website
The frequency of visiting the website

The software runs exclusively on the servers of our website. A storage of the personal data of the users only takes place there. The data will not be passed on to third parties.

The software is set up in such a way that the IP addresses are not stored completely, but 2 bytes of the IP address are masked (e.g.: 192.168.xxx.xxx). In this way, it is no longer possible to assign the shortened IP address to the calling computer.

2. Legal basis for the processing of personal data

The legal basis for the processing of users' personal data is Art. 6 para. 1 letter f DSGVO.

3. Purpose of data processing

The processing of users' personal data enables us to analyse the surfing behaviour of our users. By evaluating the data obtained, we are able to compile information on the use of the individual components of our website. This helps us to constantly improve our website and its user-friendliness. These purposes also include our legitimate interest in processing the data in accordance with Art. 6 Para. 1 lit. f DSGVO. By anonymising the IP address, the interest of the users in their protection of personal data is sufficiently taken into account.

4. Duration of storage

The data is deleted as soon as it is no longer required for our recording purposes.

5. Possibility of objection and removal

You can find more information about the privacy settings of the Matomo software under the following link: https://matomo.org/docs/privacy/.

Rights of the data subject

If personal data are processed by you, you are the person concerned within the meaning of the DSGVO and you are entitled to the following rights in relation to the person responsible:

1. Right of information

You can request confirmation from the person responsible as to whether personal data concerning you is being processed by us.

If such processing has taken place, you can request information from the data controller about the following:

the purposes for which the personal data are processed
the categories of personal data which are processed;
the recipients or categories of recipients to whom the personal data concerning you have been or will be disclosed;
the planned duration of storage of the personal data concerning you or, if it is not possible to give specific details, criteria for determining the duration of storage;
the existence of a right of rectification or erasure of personal data concerning you, a right to have the processing limited by the controller or a right to object to such processing;
the existence of a right of appeal to a supervisory authority;
any available information as to the source of the data where the personal data are not collected from the data subject;
the existence of automated decision-making, including profiling, in accordance with Art. 22 (1) and (4) DSGVO and, at least in these cases, meaningful information on the logic involved and the scope and intended impact of such processing on the data subject. You have the right to request information as to whether the personal data concerning you are being transferred to a third country or to an international organisation. In this context, you may request to be informed of the appropriate safeguards pursuant to Art. 46 DSGVO in connection with the transfer.

2. Right of rectification

You have the right to ask the data controller to correct and/or complete the data if the personal data processed concerning you is incorrect or incomplete. The data controller shall make the correction without delay.

3. Right to limit processing

Under the following conditions, you may request that the processing of personal data concerning you be restricted:

if you dispute the accuracy of the personal data concerning you for a period of time which enables the controller to verify the accuracy of the personal data;
the processing is unlawful and you object to the deletion of the personal data and instead request the restriction of the use of the personal data;
the controller no longer needs the personal data for the purposes of the processing, but you need the personal data in order to assert, exercise or defend legal claims; or
if you have lodged an objection to the processing pursuant to Art. 21 para. 1 DSGVO and it has not yet been established whether the legitimate reasons given by the controller outweigh your reasons.

If the processing of personal data relating to you has been restricted, such data may be processed, with the exception of storage, only with your consent or for the purpose of asserting, exercising or defending legal claims or protecting the rights of another natural or legal person or on grounds of an important public interest of the Union or a Member State. If the restriction on processing has been restricted in accordance with the above conditions, you will be informed by the controller before the restriction is lifted.

4. Right of cancellation

a) Duty to delete

You may request the controller to delete personal data concerning you without delay and the controller is obliged to delete such data without delay if one of the following reasons applies:

the personal data concerning you are no longer necessary for the purposes for which they were collected or otherwise processed.
you revoke your consent on which the processing was based pursuant to Art. 6 para. 1 letter a or Art. 9 para. 2 letter a DPA and there is no other legal basis for the processing.
you object to the processing pursuant to Art. 21 Paragraph 1 DSGVO and there are no legitimate reasons for the processing, or you object to the processing pursuant to Art. 21 Paragraph 2 DSGVO.
The personal data concerning you have been processed unlawfully.
The deletion of personal data concerning you is necessary to comply with a legal obligation under Union law or the law of the Member States to which the controller is subject.
The personal data concerning you have been collected in relation to information society services offered in accordance with Article 8, paragraph 1 of the DSGVO

b) Information to third parties

If the controller has made public the personal data concerning you and is obliged to delete them pursuant to Art. 17 para. 1 DPA, he shall take reasonable measures, including technical measures, taking into account the available technology and the implementation costs, to inform data controllers who process the personal data that you, as a data subject, have requested them to delete all links to these personal data or copies or replications of these personal data.

c) Exceptions

The right of cancellation does not exist insofar as the processing is necessary

on the exercise of the right to freedom of expression and information;
to comply with a legal obligation to which the processing relates under Union or national law to which the controller is subject or to carry out a task carried out in the public interest or in the exercise of official authority vested in the controller;
for reasons of public interest in the field of public health pursuant to Article 9 paragraph 2 letters h and i and Article 9 paragraph 3 of the DSGVO;
for archiving, scientific or historical research purposes in the public interest or for statistical purposes pursuant to Art. 89 para. 1 DSGVO, insofar as the law referred to in a) is likely to render impossible or seriously prejudice the attainment of the objectives of such processing, or
to assert, exercise or defend legal claims.

5. Right to information

If you have asserted the right to rectify, erase or limit the processing vis-à-vis the controller, the controller is obliged to notify all recipients to whom the personal data concerning you have been disclosed of this rectification, erasure or limitation of processing, unless this proves impossible or involves a disproportionate effort. You have the right vis-à-vis the controller to be informed of these recipients.

6. Right to data transferability

You have the right to receive the personal data concerning you that you have provided to the data controller in a structured, common and machine-readable format. You also have the right to have this data communicated to another person in charge without interference from the person in charge to whom the personal data has been communicated, provided that

the processing is based on a consent pursuant to Art. 6 para. 1 letter a DSGVO or Art. 9 para. 2 letter a DSGVO or on a contract pursuant to Art. 6 para. 1 letter b DSGVO and
the processing is carried out by means of automated procedures.

In exercising this right, you also have the right to obtain that the personal data concerning you be transferred directly from one controller to another controller, insofar as this is technically feasible. The freedoms and rights of other persons must not be affected by this. The right to data transferability shall not apply to the processing of personal data necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

7. Right of objection

You have the right to object at any time, for reasons arising from your particular situation, to the processing of personal data concerning you which is carried out pursuant to Article 6 paragraph 1 letter e or f DSGVO; this also applies to profiling based on these provisions.

The controller will no longer process the personal data concerning you, unless he can demonstrate compelling reasons for processing which are justified on grounds of protection and which outweigh your interests, rights and freedoms, or unless the processing serves to assert, exercise or defend legal claims.

If the personal data concerning you are processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing, including profiling, insofar as it is linked to such direct marketing.

If you object to processing for the purposes of direct marketing, the personal data concerning you will no longer be processed for those purposes. You have the possibility to exercise your right of objection in relation to the use of information society services, without prejudice to Directive 2002/58/EC, by using automated procedures involving technical specifications.

8. Right to revoke the declaration of consent under data protection law

You have the right to revoke your data protection declaration of consent at any time. Revocation of your consent does not affect the legality of the processing that has taken place on the basis of your consent until revocation.

9. Automated decision in individual cases

You have the right not to be subject to a decision based solely on automated processing that has legal effect against you or that significantly affects you in a similar way. This shall not apply if the decision

is necessary for the conclusion or fulfilment of a contract between you and the person responsible,
is authorised by Union or national legislation to which the person responsible is subject and that legislation provides for appropriate measures to safeguard your rights and freedoms and your legitimate interests, or
with your express consent.

However, these decisions may not be based on special categories of personal data pursuant to Art. 9 para. 1 DSGVO, unless Art. 9 para. 2 lit. a or g DSGVO applies and appropriate measures have been taken to protect rights and freedoms and your legitimate interests.

With regard to the cases referred to in (1) and (3), the data controller shall take appropriate measures to safeguard the rights and freedoms and your legitimate interests, which shall include at least the right to obtain the intervention of a person from the data controller, to present his or her point of view and to challenge the decision.

10. Right to appeal to a supervisory authority

Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State in which you are resident, your place of work or the place of the alleged infringement, if you consider that the processing of personal data concerning you is in breach of the DSGVO.

The supervisory authority to which the complaint has been lodged shall inform the complainant of the status and outcome of the complaint, including the possibility of a judicial remedy under Art. 78 DSGVO.

The supervisory authority is the State Commissioner for Data Protection and Freedom of Information of Baden-Württemberg, Königstraße 10a, 70173 Stuttgart