SPQR / Privacy policy

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Dom-Pedro-Straße 22 • 80637 München

Privacy Policy Introduction and Overview

We have written this privacy policy (version 30.01.2025-312638370) in order to explain to you, in accordance with the provisions of the General Data Protection Regulation (EU) 2016/679 and applicable national laws, which personal data (data for short) we as the controller – and the processors commissioned by us (e.g. providers) – process, will process in the future and what legal options you have. The terms used are to be considered gender-neutral.

In short: We provide you with comprehensive information about any of your personal data we process.

Privacy policies usually sound very technical and use legal terminology. However, this privacy policy is intended to describe the most important things to you as simply and transparently as possible. So long as it aids transparency, technical terms are explained in a reader-friendly manner, links to further information are provided and graphics are used. We are thus informing in clear and simple language that we only process personal data in the context of our business activities if there is a legal basis for it. This is certainly not possible with brief, unclear and legal-technical statements, as is often standard on the internet when it comes to data protection. I hope you find the following explanations interesting and informative. Maybe you will also find some information that you have not been familiar with.
If you still have questions, we kindly ask you to contact the responsible body named below or in the imprint, follow the existing links and look at further information on third-party sites. You can of course also find our contact details in the imprint.

Scope

This privacy policy applies to all personal data processed by our company and to all personal data processed by companies commissioned by us (processors). With the term personal data, we refer to information within the meaning of Article 4 No. 1 GDPR, such as the name, email address and postal address of a person. The processing of personal data ensures that we can offer and invoice our services and products, be it online or offline. The scope of this privacy policy includes:

all online presences (websites, online shops) that we operate
Social media presences and email communication
mobile apps for smartphones and other devices

In short: This privacy policy applies to all areas in which personal data is processed in a structured manner by the company via the channels mentioned. Should we enter into legal relations with you outside of these channels, we will inform you separately if necessary.

Legal bases

In the following privacy policy, we provide you with transparent information on the legal principles and regulations, i.e. the legal bases of the General Data Protection Regulation, which enable us to process personal data.

Whenever EU law is concerned, we refer to REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of April 27, 2016. You can of course access the General Data Protection Regulation of the EU online at EUR-Lex, the gateway to EU law, at https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32016R0679.

We only process your data if at least one of the following conditions applies:

Consent (Article 6 Paragraph 1 lit. a GDPR): You have given us your consent to process data for a specific purpose. An example would be the storage of data you entered into a contact form.
Contract (Article 6 Paragraph 1 lit. b GDPR): We process your data in order to fulfill a contract or pre-contractual obligations with you. For example, if we conclude a sales contract with you, we need personal information in advance.
Legal obligation (Article 6 Paragraph 1 lit. c GDPR): If we are subject to a legal obligation, we will process your data. For example, we are legally required to keep invoices for our bookkeeping. These usually contain personal data.
Legitimate interests (Article 6 Paragraph 1 lit. f GDPR): In the case of legitimate interests that do not restrict your basic rights, we reserve the right to process personal data. For example, we have to process certain data in order to be able to operate our website securely and economically. Therefore, the processing is a legitimate interest.

Other conditions such as making recordings in the interest of the public, the exercise of official authority as well as the protection of vital interests do not usually occur with us. Should such a legal basis be relevant, it will be disclosed in the appropriate place.

In addition to the EU regulation, national laws also apply:

In Austria this is the Austrian Data Protection Act (Datenschutzgesetz), in short DSG.
In Germany this is the Federal Data Protection Act (Bundesdatenschutzgesetz), in short BDSG.

Should other regional or national laws apply, we will inform you about them in the following sections.

Contact details of the data protection controller

If you have any questions about data protection or the processing of personal data, you will find below the contact details of the controller in accordance with Article 4(7) of the EU General Data Protection Regulation (GDPR):

SPQR Informatik GmbH
Armin Öllinger
Dom-Pedro-Straße 22
80637 München
Deutschland

E-Mail: armin.oellinger@spqr-info.de
Phone: +49 89 15780055
Company details: https://www.spqr-info.de/Imprint

Storage Period

It is a general criterion for us to store personal data only for as long as is absolutely necessary for the provision of our services and products. This means that we delete personal data as soon as any reason for the data processing no longer exists. In some cases, we are legally obliged to keep certain data stored even after the original purpose no longer exists, such as for accounting purposes.

If you want your data to be deleted or if you want to revoke your consent to data processing, the data will be deleted as soon as possible, provided there is no obligation to continue its storage.

We will inform you below about the specific duration of the respective data processing, provided we have further information.

Rights in accordance with the General Data Protection Regulation

In accordance with Articles 13, 14 of the GDPR, we inform you about the following rights you have to ensure fair and transparent processing of data:

According to Article 15 DSGVO, you have the right to information about whether we are processing data about you. If this is the case, you have the right to receive a copy of the data and to know the following information:
for what purpose we are processing;
the categories, i.e. the types of data that are processed;
who receives this data and if the data is transferred to third countries, how security can be guaranteed;
how long the data will be stored;
the existence of the right to rectification, erasure or restriction of processing and the right to object to processing;
that you can lodge a complaint with a supervisory authority (links to these authorities can be found below);
the origin of the data if we have not collected it from you;
Whether profiling is carried out, i.e. whether data is automatically evaluated to arrive at a personal profile of you.
You have a right to rectification of data according to Article 16 GDPR, which means that we must correct data if you find errors.
You have the right to erasure (“right to be forgotten”) according to Article 17 GDPR, which specifically means that you may request the deletion of your data.
According to Article 18 of the GDPR, you have the right to restriction of processing, which means that we may only store the data but not use it further.
According to Article 20 of the GDPR, you have the right to data portability, which means that we will provide you with your data in a standard format upon request.
According to Article 21 DSGVO, you have the right to object, which entails a change in processing after enforcement.
If the processing of your data is based on Article 6(1)(e) (public interest, exercise of official authority) or Article 6(1)(f) (legitimate interest), you may object to the processing. We will then check as soon as possible whether we can legally comply with this objection.
If data is used to conduct direct advertising, you may object to this type of data processing at any time. We may then no longer use your data for direct marketing.
If data is used to conduct profiling, you may object to this type of data processing at any time. We may no longer use your data for profiling thereafter.
According to Article 22 of the GDPR, you may have the right not to be subject to a decision based solely on automated processing (for example, profiling).
You have the right to lodge a complaint under Article 77 of the GDPR. This means that you can complain to the data protection authority at any time if you believe that the data processing of personal data violates the GDPR.

In short: you have rights – do not hesitate to contact the responsible party listed above with us!

If you believe that the processing of your data violates data protection law or your data protection rights have been violated in any other way, you can complain to the supervisory authority. For Austria, this is the data protection authority, whose website can be found at https://www.dsb.gv.at/. In Germany, there is a data protection officer for each federal state. For more information, you can contact the Federal Commissioner for Data Protection and Freedom of Information (BfDI). The following local data protection authority is responsible for our company:

Bayern Data protection authority

State Commissioner for Data Protection: Prof. Dr. Thomas Petri
Address: Wagmüllerstr. 18, 80538 München
Phone number: +49 89 212672-0
E-mail address: poststelle@datenschutz-bayern.de

Website: https://www.datenschutz-bayern.de/

Security of data processing operations

In order to protect personal data, we have implemented both technical and organisational measures. We encrypt or pseudonymise personal data wherever this is possible. Thus, we make it as difficult as we can for third parties to extract personal information from our data.

Article 25 of the GDPR refers to “data protection by technical design and by data protection-friendly default” which means that both software (e.g. forms) and hardware (e.g. access to server rooms) appropriate safeguards and security measures shall always be placed. If applicable, we will outline the specific measures below.

TLS encryption with https

The terms TLS, encryption and https sound very technical, which they are indeed. We use HTTPS (Hypertext Transfer Protocol Secure) to securely transfer data on the Internet.
This means that the entire transmission of all data from your browser to our web server is secured – nobody can “listen in”.

We have thus introduced an additional layer of security and meet privacy requirements through technology design Article 25 Section 1 GDPR. With the use of TLS (Transport Layer Security), which is an encryption protocol for safe data transfer on the internet, we can ensure the protection of confidential information.
You can recognise the use of this safeguarding tool by the little lock-symbol 🔒, which is situated in your browser’s top left corner in the left of the internet address (e.g. examplepage.uk), as well as by the display of the letters https (instead of http) as a part of our web address.
If you want to know more about encryption, we recommend you to do a Google search for “Hypertext Transfer Protocol Secure wiki” to find good links to further information.

Communications

Communications Overview

👥 Affected parties: Anyone who communicates with us via phone, email or online form
🤝 Processed data: e. g. telephone number, name, email address or data entered in forms. You can find more details on this under the respective form of contact
📓 Purpose: handling communication with customers, business partners, etc.
📅 Storage duration: for the duration of the business case and the legal requirements
⚖️ Legal basis: Article 6 (1) (a) GDPR (consent), Article 6 (1) (b) GDPR (contract), Article 6 (1) (f) GDPR (legitimate interests)

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If you contact us and communicate with us via phone, email or online form, your personal data may be processed.

The data will be processed for handling and processing your request and for the related business transaction. The data is stored for this period of time or for as long as is legally required.

Affected persons

The above-mentioned processes affect all those who seek contact with us via the communication channels we provide.

Telephone

When you call us, the call data is stored in a pseudonymised form on the respective terminal device, as well as by the telecommunications provider that is being used. In addition, data such as your name and telephone number may be sent via email and stored for answering your inquiries. The data will be erased as soon as the business case has ended and the legal requirements allow for its erasure.

Email

If you communicate with us via email, your data is stored on the respective terminal device (computer, laptop, smartphone, …) as well as on the email server. The data will be deleted as soon as the business case has ended and the legal requirements allow for its erasure.

Online forms

If you communicate with us using an online form, your data is stored on our web server and, if necessary, forwarded to our email address. The data will be erased as soon as the business case has ended and the legal requirements allow for its erasure.

Legal bases

Data processing is based on the following legal bases:

Art. 6 para. 1 lit. a GDPR (consent): You give us your consent to store your data and to continue to use it for the purposes of the business case;
Art. 6 para. 1 lit. b GDPR (contract): For the performance of a contract with you or a processor such as a telephone provider, or if we have to process the data for pre-contractual activities, such as preparing an offer;
Art. 6 para. 1 lit. f GDPR (legitimate interests): We want to conduct our customer inquiries and business communication in a professional manner. Thus, certain technical facilities such email programs, Exchange servers and mobile network operators are necessary to efficiently operate our communications.

Web hosting

Web hosting Overview

👥 Affected parties: visitors to the website
📓 Purpose: professional hosting of the website and security of operations
🤝 Processed data: IP address, time of website visit, browser used and other data. You can find more details on this below or at the respective web hosting provider.
📅 Storage period: dependent on the respective provider, but usually 2 weeks
⚖️ Legal basis: Art. 6 para. 1 lit. f GDPR (legitimate interests)

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What is web hosting?

Every time you visit a website nowadays, certain information – including personal data – is automatically created and stored, including on this website. This data should be processed as sparingly as possible, and only with good reason. By website, we mean the entirety of all websites on your domain, i.e. everything from the homepage to the very last subpage (like this one here). By domain we mean example.uk or examplepage.com.

When you want to view a website on a screen, you use a program called a web browser. You probably know the names of some web browsers: Google Chrome, Microsoft Edge, Mozilla Firefox, and Apple Safari.

The web browser has to connect to another computer which stores the website’s code: the web server. Operating a web server is complicated and time-consuming, which is why this is usually done by professional providers. They offer web hosting and thus ensure the reliable and flawless storage of website data.

Whenever the browser on your computer establishes a connection (desktop, laptop, smartphone) and whenever data is being transferred to and from the web server, personal data may be processed. After all, your computer stores data, and the web server also has to retain the data for a period of time in order to ensure it can operate properly.

Why do we process personal data?

The purposes of data processing are:

Professional hosting of the website and operational security
To maintain the operational as well as IT security
Anonymous evaluation of access patterns to improve our offer, and if necessary, for prosecution or the pursuit of claims.li>

Which data are processed?

Even while you are visiting our website, our web server, that is the computer on which this website is saved, usually automatically saves data such as

the full address (URL) of the accessed website (e. g. https://www.examplepage.uk/examplesubpage.html?tid=312638370)
browser and browser version (e.g. Chrome 87)
the operating system used (e.g. Windows 10)
the address (URL) of the previously visited page (referrer URL) (e. g. https://www.examplepage.uk/icamefromhere.html/)
the host name and the IP address of the device from the website is being accessed from (e.g. COMPUTERNAME and 194.23.43.121)
date and time
in so-called web server log files

How long is the data stored?

Generally, the data mentioned above are stored for two weeks and are then automatically deleted. We do not pass these data on to others, but we cannot rule out the possibility that this data may be viewed by the authorities in the event of illegal conduct.

In short: Your visit is logged by our provider (company that runs our website on special computers (servers)), but we do not pass on your data without your consent!

Legal basis

The lawfulness of processing personal data in the context of web hosting is justified in Art. 6 para. 1 lit. f GDPR (safeguarding of legitimate interests), as the use of professional hosting with a provider is necessary to present the company in a safe and user-friendly manner on the internet, as well as to have the ability to track any attacks and claims, if necessary.

Amazon Web Services (AWS) Privacy Policy

We use Amazon Web Services (AWS) for our website, which is a web hosting provider, among other things. The provider of this service is the American company Amazon Web Services, Inc., 410 Terry Avenue North, Seattle WA 98109, USA.

Amazon processes data from you, among other things, in the USA. Amazon is an active participant in the EU-US Data Privacy Framework, which regulates the correct and secure transfer of personal data from EU citizens to the USA. More information can be found at https://commission.europa.eu/document/fa09cbad-dd7d-4684-ae60-be03fcb0fddf_en.

Additionally, Amazon uses so-called Standard Contractual Clauses (Article 46(2) and (3) GDPR). Standard Contractual Clauses (SCC) are template clauses provided by the EU Commission and are designed to ensure that your data complies with European data protection standards, even when transferred and stored in third countries (such as the USA). Through the EU-US Data Privacy Framework and the Standard Contractual Clauses, Amazon commits to maintaining the European data protection level when processing your relevant data, even if the data is stored, processed, and managed in the USA. These clauses are based on an implementing decision of the EU Commission. You can find the decision and the corresponding Standard Contractual Clauses here: https://ec.europa.eu/commission/presscorner/detail/en/ip_21_2847.

The Amazon data processing terms and conditions (Data Processing Addendum), which correspond to the standard contractual clauses, can be found at https://d1.awsstatic.com/legal/aws-gdpr/AWS_GDPR_DPA.pdf.

You can find out more about the data that are processed through the use of Amazon Web Services (AWS) in their Privacy Policy at https://aws.amazon.com/privacy/?nc1=h_ls.

Data Processing Agreement (DPA) Amazon Web Services (AWS)

In accordance with Article 28 of the General Data Protection Regulation (GDPR), we have entered into a Data Processing Agreement (DPA) with Amazon Web Services (AWS). What exactly a DPA is and especially what must be included in a DPA, you can read in our general section “Data Processing Agreement (DPA)”.

This contract is required by law because Amazon Web Services (AWS) processes personal data on our behalf. It clarifies that Amazon Web Services (AWS) may only process data they receive from us according to our instructions and must comply with the GDPR. You can find the link to the Data Processing Agreement (DPA) under https://d1.awsstatic.com/legal/aws-gdpr/AWS_GDPR_DPA.pdf.

Webhosting Other

Contact data for our Webhosting: Without Code / www.wocode.com

You can learn more about the data processing at this provider in their Privacy Policy.

Closing Remarks

Congratulations! If you are reading these lines, you have most likely familiarised yourself with our entire Privacy Policy – or at least scrolled down here. As you can see from the scope of our Privacy Policy, we do not take the protection of your personal data lightly.

We find it important to inform you about the processing of your personal data to the best of our abilities. In doing so, we not only want to tell you which data is processed but also explain to you why we use various software programs. In general, Privacy Policies have very technical and legal jargon. However, since most of you are not web developers or solicitors, we wanted to take a different approach and explain the facts in simple and clear language. Of course, this is not always possible due to the subject matter. Therefore, you can also find a more detailed explanation of the most important terms at the end of the Privacy Policy.

If you have any questions about data protection on our website, please do not hesitate to contact us or the responsible body. We wish you all the best and hope to soon welcome you to our website again.

Privacy Policy