SPÜLBOY®

Privacy Policy

Preamble

With the following privacy policy we would like to inform you which types of your personal data (hereinafter also abbreviated as “data”) we process for which purposes and in which scope. The privacy statement applies to all processing of personal data carried out by us, both in the context of providing our services and in particular on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as “online services”).

The terms used are not gender-specific.

Last Update: 10. September 2025

Table of contents

  • Preamble
  • Controller
  • Overview of processing operations
  • Legal Bases for the Processing
  • Security Precautions
  • Transmission and Disclosure of Personal Data
  • Data Processing in Third Countries
  • Use of Cookies
  • Commercial Services
  • Use of Online Marketplaces for E-Commerce
  • Payment Service Provider
  • Provision of online services and web hosting
  • Registration, Login and User Account
  • Blogs and publication media
  • Contacting us
  • Newsletter and Electronic Communications
  • Commercial communication by E-Mail, Postal Mail, Fax or Telephone
  • Sweepstakes and Contests
  • Surveys and Questionnaires
  • Web Analysis, Monitoring and Optimization
  • Onlinemarketing
    Affiliate-Programms and Affiliate-Links
  • Rating Platforms
    Profiles in Social Networks (Social Media)
  • Plugins and embedded functions and content
  • Planning, Organization and Utilities
  • Erasure of data
  • Changes and Updates to the Privacy Policy
  • Rights of Data Subjects
  • Terminology and Definitions

Overview of processing operations

The following table summarises the types of data processed, the purposes for which
they are processed and the concerned data subjects.

Categories of Processed Data

  • Contact Information (Facebook) (“Contact Information” is data that (clearly)
    identifies data subjects, such as names, email addresses and phone numbers,
    that can be transmitted to Facebook, e.g. via Facebook pixels or uploads for
    matching purposes to form Custom Audiences; After the matching to create
    target groups, the Contact Information is deleted).
  • Inventory data (e.g. names, addresses).
  • Content data (e.g. text input, photographs, videos).
  • Contact data (e.g. e-mail, telephone numbers).
  • Meta/communication data (e.g. device information, IP addresses).
  • Usage data (e.g. websites visited, interest in content, access times).
  • Social data (Data subject to a special social confidentiality obligation and
    processed, for example, by social insurance institutions, social welfare
    institutions or pension authorities.).
  • Location data (Information on the geographical position of a device or
    person).
  • Contract data (e.g. contract object, duration, customer category).
  • Payment Data (e.g. bank details, invoices, payment history).

Categories of Data Subjects

  • Employees (e.g. Employees, job applicants).
  • Business and contractual partners.
  • Prospective customers.
  • Communication partner (Recipients of e-mails, letters, etc.).
  • Customers.
    Users (e.g. website visitors, users of online services).
  • Participants in sweepstakes and competitions.

Purposes of Processing

  • Affiliate Tracking.
  • Provision of our online services and usability.
  • Conversion tracking (Measurement of the effectiveness of marketing
    activities).
  • Office and organisational procedures.
  • Clicktracking.
  • Content Delivery Network (CDN).
  • Cross-Device Tracking (Device-independent processing of user data for
    marketing purposes).
  • Direct marketing (e.g. by e-mail or postal).
  • Conducting sweepstakes and contests.
  • Feedback (e.g. collecting feedback via online form).
  • Interest-based and behavioral marketing.
    Contact requests and communication.
    Profiling (Creating user profiles).
  • Remarketing.
    Web Analytics (e.g. access statistics, recognition of returning visitors).
  • Security measures.
  • Targeting (e.g. profiling based on interests and behaviour, use of cookies).
  • Provision of contractual services and customer support.
  • Managing and responding to inquiries.
  • Custom Audiences (Selection of relevant target groups for marketing
    purposes or other output of content).

Legal Bases for the Processing

In the following we inform you about the legal basis of the General Data Protection
Regulation (GDPR), on the basis of which we process personal data. Please note
that, in addition to the regulations of the GDPR, the national data protection
regulations may apply in your country or in our country of residence or domicile. If,
in addition, more specific legal bases are applicable in individual cases, we will
inform you of these in the data protection declaration.

  • Consent (Article 6 (1) (a) GDPR) – The data subject has given consent to
    the processing of his or her personal data for one or more specific purposes.
  • Performance of a contract and prior requests (Article 6 (1) (b) GDPR) –
    Performance of a contract to which the data subject is party or in order to
    take steps at the request of the data subject prior to entering into a contract.
  • Compliance with a legal obligation (Article 6 (1) (c) GDPR) – Processing
    is necessary for compliance with a legal obligation to which the controller is
    subject.
  • Legitimate Interests (Article 6 (1) (f) GDPR) – Processing is necessary for
    the purposes of the legitimate interests pursued by the controller or by a
    third party, except where such interests are overridden by the interests or
    fundamental rights and freedoms of the data subject which require protection
    of personal data.

National data protection regulations in Germany: In addition to the data
protection regulations of the General Data Protection Regulation, national
regulations apply to data protection in Germany. This includes in particular the Law
on Protection against Misuse of Personal Data in Data Processing (Federal Data
Protection Act – BDSG). In particular, the BDSG contains special provisions on the
right to access, the right to erase, the right to object, the processing of special
categories of personal data, processing for other purposes and transmission as well
as automated individual decision-making, including profiling. Furthermore, it
regulates data processing for the purposes of the employment relationship (ยง 26
BDSG), in particular with regard to the establishment, execution or termination of
employment relationships as well as the consent of employees. Furthermore, data
protection laws of the individual federal states may apply.

Security Precautions

We take appropriate technical and organisational measures in accordance with the
legal requirements, taking into account the state of the art, the costs of
implementation and the nature, scope, context and purposes of processing as well
as the risk of varying likelihood and severity for the rights and freedoms of natural
persons, in order to ensure a level of security appropriate to the risk.

The measures include, in particular, safeguarding the confidentiality, integrity and
availability of data by controlling physical and electronic access to the data as well
as access to, input, transmission, securing and separation of the data. In addition,
we have established procedures to ensure that data subjects’ rights are respected,
that data is erased, and that we are prepared to respond to data threats rapidly.
Furthermore, we take the protection of personal data into account as early as the
development or selection of hardware, software and service providers, in
6 accordance with the principle of privacy by design and privacy by default.

Masking of the IP address: If it is possible for us or the storage of the IP address
is not necessary, we shorten or have your IP address shortened. When the IP
address is shortened, also known as “IP masking”, the last octet, i.e. the last two
numbers of an IP address, is deleted (the IP address in this context is an identifier
individually assigned to an Internet connection by the online access provider). With
the shortening of the IP address, the identification of a person on the basis of their
IP address is to be prevented or made considerably more difficult.

SSL encryption (https): In order to protect your data transmitted via our online
services in the best possible way, we use SSL encryption. You can recognize such
encrypted connections by the prefix https:// in the address bar of your browser.

Transmission and Disclosure of Personal Data

In the context of our processing of personal data, it may happen that the data is
transferred to other places, companies or persons or that it is disclosed to them.
Recipients of this data may include, for example, payment institutions within the
context of payment transactions, service providers commissioned with IT tasks or
providers of services and content that are embedded in a website. In such a case,
the legal requirements will be respected and in particular corresponding contracts
or agreements, which serve the protection of your data, will be concluded with the
recipients of your data.

Use of Cookies

Cookies are text files that contain data from visited websites or domains and are
stored by a browser on the user’s computer. A cookie is primarily used to store
information about a user during or after his visit within an online service. The
information stored can include, for example, the language settings on a website, the
login status, a shopping basket or the location where a video was viewed. The term
“cookies” also includes other technologies that fulfil the same functions as cookies
(e.g. if user information is stored using pseudonymous online identifiers, also
referred to as “user IDs”).

The following types and functions of cookies are distinguished:

  • Temporary cookies (also: session cookies): Temporary cookies are
    deleted at the latest after a user has left an online service and closed his
    browser.
  • Permanent cookies: Permanent cookies remain stored even after closing the
    browser. For example, the login status can be saved or preferred content can
    be displayed directly when the user visits a website again. The interests of
    users who are used for range measurement or marketing purposes can also
    be stored in such a cookie.
  • First-Party-Cookies: First-Party-Cookies are set by ourselves.
  • Third party cookies: Third party cookies are mainly used by advertisers (socalled third parties) to process user information.
  • Necessary (also: essential) cookies: Cookies can be necessary for the
    operation of a website (e.g. to save logins or other user inputs or for security
    reasons).
  • Statistics, marketing and personalisation cookies: Cookies are also
    generally used to measure a website’s reach and when a user’s interests or
    behaviour (e.g. viewing certain content, using functions, etc.) are stored on
    individual websites in a user profile. Such profiles are used, for example, to
    display content to users that corresponds to their potential interests. This
    procedure is also referred to as “tracking”, i.e. tracking the potential interests
    of users. If we use cookies or “tracking” technologies, we will inform you
    separately in our privacy policy or in the context of obtaining consent.
  • Information on legal basis: The legal basis on which we process your personal
    data with the help of cookies depends on whether we ask you for your consent. If
    this applies and you consent to the use of cookies, the legal basis for processing
    your data is your declared consent. Otherwise, the data processed with the help of
    cookies will be processed on the basis of our legitimate interests (e.g. in a business
    operation of our online service and its improvement) or, if the use of cookies is
    8 necessary to fulfill our contractual obligations.
  • Retention period: Unless we provide you with explicit information on the
    retention period of permanent cookies (e.g. within the scope of a so-called cookie
    opt-in), please assume that the retention period can be as long as two years