INTRODUCTION AND TERMS
By operating our website www.sparc-europe.com (hereinafter referred to as "website"), we process personal data. These are treated confidentially by us and processed in accordance with the applicable laws - in particular the German Data Protection Regulation (DSGVO) and the German Federal Data Protection Act (BDSG-neu). With our data protection regulations, we want to inform you which personal data we collect from you, for what purposes and on what legal basis we use it and, if applicable, to whom we disclose it. In addition, we will explain to you what rights you have to protect and enforce your data protection.
Our data protection provisions contain technical terms that are in the DSGVO and the BDSG-neu. For your better understanding, we would like to explain these terms in simple terms in advance:
2.1 Personal data
"Personal data" means any information relating to an identified or identifiable person (Art. 4 No. 1 DSGVO). Information of an identified person can be, for example, the name or the e-mail address. However, personal data is also data for which the identity is not immediately apparent, but can be determined by combining one's own information or that of others and thus finding out who it is. A person can be identified, for example, by providing his or her address or bank details, date of birth or user name, IP addresses and/or location data. Relevant here is all information that in any way allows a conclusion to be drawn about a person.
Article 4 No. 2 GDPR understands "processing" to mean any operation in connection with personal data. This applies in particular to the collection, recording, organisation, arrangement, storage, adaptation or alteration, retrieval, consultation, use, disclosure, transfer, dissemination or any other form of making available, alignment or combination, restriction, erasure or destruction of personal data.
RESPONSIBLE COMPANY AND DATA PROTECTION OFFICER
3. RESPONSIBLE PARTY
The person responsible for data processing is:
Company: RPP Group SRL ("we")
Legal representative: Yordan Aleksandrov (managing director)
Address: Rue Guimard 10, 1040 Brussels, Belgium
Telephone: +32 2743 2890
4. DATA PROTECTION OFFICER
We have appointed an external data protection officer for our company. You can reach him under:
Name: Loubna Ouriaghli
Address: RPP Group SRL, Rue Guimard 10, 1040 Brussels, Belgium
Telephone: +32 2743 2890
5. PROCESSING FRAMEWORK: WEBSITE
Within the framework of the website with the URL www.sparc-europe.com we process the personal data of you listed in detail below under point 6-59. We only process data from you that you actively provide on our website (e.g. by filling in forms) or that you provide automatically when using our offer.
Your data will only be processed by us and will not be sold, lent or passed on to third parties. If we use the help of external service providers to process your personal data, this is done within the framework of so-called order processing, in which we as the client are authorized to issue instructions to our contractors. For the operation of our website, we use external service providers for hosting, as well as for maintenance, care and further development. If further external service providers are used for individual processing operations listed in sections 6-59, they will be named there.
Data transfer to third countries does not take place and is not planned. We will provide information on exceptions to this principle in the processing operations described below.
THE PROCESSING IN DETAIL
6. PROVISION OF THE WEBSITE AND SERVER LOG FILES
6.1 Description of the processing
Each time you access the website, we automatically collect information that your browser transmits to our server (so-called log files). This involves the following data:
- Your IP address
- the browser software you use, as well as its version and language
- the operating system you use
- the website from which you came to our website (so-called referrer)
- the sub-pages you have accessed on our website
- the date and time of your visit to our website
- your internet service provider
- The amount of data transferred
- Country and place from which you visited our website
- Your length of stay on our website
These are also stored in the so-called log files of our system. The temporary storage of your IP address by the system is necessary in order to be able to deliver our website to the end device of a user. For this purpose, the user's IP address must remain stored for the duration of the session. However, your IP address is only recorded in the log files shortened by the last three digits.
The processing is carried out to enable the website to be called up and to ensure its stability and security. Furthermore, the processing serves the statistical evaluation and improvement of our online offer.
6.3 Legal basis
The processing is necessary to protect the overriding legitimate interests of the controller (Art. 6 para. 1 lit. f DSGVO). Our legitimate interest lies in the purpose named in section 6.2.
6.4 Storage period
The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. In the case of the collection of data for the provision of the website, this is the case when the respective session has ended. The log files are deleted after 7 days.
7. CONTACT FORM AND CONTACT BY E-MAIL
7.1 Description of the processing
To contact us, we have provided a contact form on our website. In this form, you are asked to enter your e-mail address, your name and a message to us. When you click the "Send" button, the data will be transmitted to us using SSL encryption (see section 59). The contact form can only be transmitted if you accept our data protection provisions by clicking the corresponding checkbox. You can also contact us via the e-mail addresses provided on the website. In this case, the personal data transmitted with the e-mail will be processed by us.
By providing a contact form on our website, we want to offer you a convenient way to contact us. The data transmitted with and in the contact form or your e-mail will be used exclusively for the purpose of processing and responding to your request.
7.3 Legal basis
The processing is necessary to protect the overriding legitimate interests of the controller (Art. 6 (1) (f) DSGVO). Our legitimate interest lies in the purpose stated in section 9.2. If the e-mail contact is aimed at the conclusion or fulfilment of a contract, the data processing is carried out for the fulfilment of the contract (Art. 6 para. 1 lit. b DSGVO).
7.4 Storage period
We delete the data as soon as it is no longer required to achieve the purpose for which it was collected. This is usually the case when the respective communication with you has ended. The communication is deemed to have ended when it is clear from the circumstances that your concern has been conclusively clarified. If legal retention periods prevent deletion, the data will be deleted immediately after expiry of the legal retention period.
8.1 Description of processing
You can find out which cookies are used on our website for which purpose, how long they are stored on your end device and which consents you may have already declared in the settings of the Consent Tool. To access the settings click on cookie settings on the bottom right corner of the website footer.
8.3 Legal basis
The processing is necessary with regard to technically required cookies, as well as the use of the Consent Tool to protect the overriding legitimate interests of the controller (Art. 6 (1) lit. f DSGVO). Our legitimate interest lies in the purpose named in section 8.2. With regard to the processing of all other cookies - i.e. cookies that are not technically necessary - the legal basis is consent (Art. 6 (1) a DSGVO). Such consent is voluntary.
8.4 Storage period, revocation of consent
8.5 Recipients and transmission to third countries
When using third-party cookies, data may be transmitted to the corresponding providers of these third-party services. Under certain circumstances, data may also be transferred to third countries outside the European Union or the European Economic Area. We provide information about the recipients of data and the transfer of data to third countries in the settings of the Consent Tool or in the corresponding passage on the third-party service in these data protection provisions.
9. ADOBE TYPEKIT
9.1 Description of processing
The processing is done in order to display the text of our website in a more readable and aesthetically pleasing way.
9.3 Legal basis
The processing is necessary to protect the overriding legitimate interests of the controller (Art. 6(1)(f) DSGVO). Our legitimate interest lies in the purpose named in section 16.2.
9.4 Recipients and transfer to third countries
Through the use of Adobe Typekit, personal data may be transmitted to Adobe. Adobe also processes your personal data in the USA, where applicable through the group company Adobe Systems Incorporated, San Francisco, 345 Park Avenue, San Jose, California 95110, USA.
10. GOOGLE ANALYTICS
10.1 Description of the processing
The processing takes place in order to be able to evaluate the use of our website. The information thus obtained is used to improve our online presence and to design it in line with requirements.
10.3 Legal basis
The processing is carried out on the basis of consent in accordance with Art. 6 Para. 1 lit. a DSGVO. This is obtained by us via a consent tool. Such consent is voluntary.
10.4 Storage period and right of objection, revocation of consent
10.5 Recipients and transmission to third countries
According to the German data protection supervisory authorities (Data Protection Conference), Google Analytics is jointly responsible for data processing on our behalf. Against this background, we have also concluded the "Google Measurement Controller-Controller Data Protection Terms" with Google. Google also processes your personal data in the USA.
11. GOOGLE TAG MANAGER
Our website uses the "Google Tag Manager", a service provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (hereinafter referred to as "Google"). No personal data is collected via the Google Tag Manager and no cookies are set. This service only enables us to integrate and manage tags on our website. Tags are small code elements on our website that are useful to measure traffic and visitor behaviour based on them with other tools, to measure the impact of online advertising and social channels, to use remarketing and targeting, to test and optimise the website. More information on Google Tag Manager can be found here: www.google.com/intl/de/tagmanager/use-policy.html
12. GOOGLE RECAPTCHA
12.1 Description of the processing
Our website uses "reCAPTCHA", a service operated by Google LLC, 1600 Amphitheatre Parkway, Mountain View, California 94043, USA (hereinafter referred to as "Google"). With reCAPTCHA, we can check in the context of forms whether the input is made by a human or by automated software - in particular so-called bots. This enables us to protect our website from spam and misuse. In this context, your IP address, the time you spend on the website, mouse movements you make and possibly other data required for the reCAPTCHA service are transmitted to Google. Further information on data protection at Google can be found at policies.google.com/privacy .
The processing takes place in order to protect forms on our website against misuse and spam.
12.3 Legal basis
The processing is necessary to protect the overriding legitimate interests of the controller (Art. 6(1)(f) DSGVO). Our legitimate interest lies in the purpose named in section 12.2.
12.4 Recipients and transfer to third countries
Google also processes your personal data in the USA.
13. GOOGLE ADSENSE
13.1 Description of processing
Our website uses Google AdSense, a service that selects advertisements matching the content of our website provided by Google LLC ("Google"). The provider is Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. In addition to the content context, AdSense also supports interest-based targeting based on the individual profile of a visitor to our website or ad. Google AdSense uses "cookies", which are text files placed on your computer, to help the website analyse how users use the site. Google AdSense also uses so-called web beacons (invisible graphics). Through these web beacons, information such as visitor traffic on these pages can be analysed. The information generated by cookies and web beacons about the use of this website (including your IP address) and delivery of advertising formats will be transmitted to and stored by Google on servers in the United States. This information may be passed on by Google to contractual partners of Google. However, Google will not merge your IP address with other data stored by you.
The processing is carried out in order to be able to offer you the most relevant advertising possible, to increase the attractiveness of our website and to optimise our advertising offer.
13.3 Legal basis
The processing is based on consent pursuant to Art. 6 (1) a DSGVO. This is obtained by us via a consent tool. Such consent is voluntary.
13.4 Storage period and right of objection, revocation of consent
13.5 Recipients and transmission to third countries
Google Adsense acts as a service provider for us within the framework of order processing. Google also processes your personal data in the USA.
14. DOUBLECLICK BY GOOGLE
14.1 Description of the processing
The use of DoubleClick cookies only enables Google and its partner websites to serve ads based on previous visits to our website or other websites on the Internet.
14.3 Legal basis
The processing is based on consent pursuant to Art. 6 (1) a DSGVO. This is obtained by us via a consent tool. Such consent is voluntary.
14.4 Storage period and right of objection, revocation of consent
14.5 Recipients and transmission to third countries
15. DATA SUBJECT RIGHTS
With regard to the data processing by our company described above, you are entitled to the following data subject rights:
15.1 Information (Art. 15 DSGVO).
You have the right to request confirmation from us as to whether we are processing personal data relating to you. If this is the case, you have a right to information about this personal data and to the further information listed in Art. 15 DSGVO under the conditions specified in Art. 15 DSGVO.
15.2 Correction (Art. 16 DSGVO)
You have the right to request that we correct any inaccurate personal data relating to you without undue delay and, where applicable, to complete any incomplete personal data.
15.3 Deletion (Art. 17 DSGVO)
You have the right to request that we delete personal data relating to you without undue delay, provided that one of the reasons listed in detail in Art. 17 DSGVO applies, e.g. if your data is no longer required for the purposes pursued by us.
15.4 Restriction of data processing (Art. 18 DSGVO)
You have the right to request us to restrict processing if one of the conditions listed in Art. 18 DSGVO applies, e.g. if you dispute the accuracy of your personal data, data processing will be restricted for the period of time that allows us to verify the accuracy of your data.
15.5 Data portability (Art. 20 DSGVO)
You have the right, under the conditions set out in Art. 20 DSGVO, to request that the data relating to you be handed over in a structured, common and machine-readable format.
15.6 Withdrawal of consent (Art. 7 (3) DSGVO)
You have the right to revoke your consent at any time in the case of processing based on consent. The revocation applies from the time it is asserted. In other words, it is effective for the future. The processing does not therefore become unlawful retroactively as a result of the withdrawal of consent.
15.7 Complaint (Art. 77 GDPR)
If you believe that the processing of personal data concerning you violates the GDPR, you have the right to lodge a complaint with a supervisory authority. You may exercise this right before a supervisory authority in the EU Member State of your place of residence, place of work or place of the alleged infringement.
15.8 Prohibition of automated decisions/profiling (Art. 22 GDPR)
Decisions which have legal effects concerning you or which significantly affect you must not be based solely on automated processing of personal data, including profiling. We inform you that we do not use automated decision-making, including profiling, with regard to your personal data.
15.9 Objection (Art. 21 DSGVO)
If we process personal data from you on the basis of Art. 6(1)(f) DSGVO (for the protection of overriding legitimate interests), you have the right to object to this under the conditions listed in Art. 21 DSGVO. However, this only applies insofar as there are reasons arising from your particular situation. After an objection, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for processing that override your interests, rights and freedoms. We also do not have to stop processing if it serves the assertion, exercise or defence of legal claims. In any case - also irrespective of a specific situation - you have the right to object at any time to the processing of your personal data for direct marketing.
Status: April 2021