Data protection policy

In accordance with the legal requirements of data protection law (in particular in accordance with BDSG n.F. and the European Data Protection Regulation ‚DS-GVO‘), we inform you below about the nature, scope and purpose of the processing of personal data by our company. This privacy policy also applies to our websites and social media profiles. Regarding the definition of terms such as „personal data“ or „processing“, we refer to Art. 4 DS-GVO.

Name and contact details of the responsible person(s)
Our responsible person(s) (hereinafter „responsible person“) within the meaning of Art. 4 fig. 7 DS-GVO is:

Andreas Streubig-Spiegel
Zwickmöhlen 23 a
22844 Norderstedt Germany
Managing Director Andreas Streubig-Spiegel
E-mail address:

Types of data, purposes of processing and categories of data subjects

In the following, we inform you about the type, scope and purpose of the collection, processing and use of personal data.

  1. types of data we process
    Contact data (telephone number, e-mail, fax, etc.), communication data (IP address, etc.),
  2. purposes of processing according to Art. 13 para. 1 c) DS-GVO
    Evidence purposes / preservation of evidence, optimize website technically and economically, enable easy access to the website, contact in case of legal complaint by third parties, fulfill legal retention obligations, avoid SPAM and abuse, customer service and customer care, handle contact requests,
  3. categories of data subjects according to Art. 13 (1) e) DS-GVO
    Visitors/users of the website, applicants,

The data subjects are collectively referred to as „users“.

Legal basis for the processing of personal data

Below we inform you about the legal basis for the processing of personal data:

  1. If we have obtained your consent for the processing of personal data, Art. 6 (1) p. 1 lit. a) DS-GVO is the legal basis.
  2. If the processing is necessary for the performance of a contract or for the implementation of pre-contractual measures, which are carried out at your request, Art. 6 (1) S. 1 lit. b) DS-GVO is the legal basis.
  3. If the processing is necessary for the fulfillment of a legal obligation to which we are subject (e.g. legal retention obligations), Art. 6 (1) p. 1 lit. c) DS-GVO is the legal basis.
  4. If the processing is necessary to protect vital interests of the data subject or another natural person, Art. 6 (1) p. 1 lit. d) DS-GVO is the legal basis.
  5. If the processing is necessary to protect our or a third party’s legitimate interests and your interests or fundamental rights and freedoms do not override this, Art. 6 (1) S. 1 lit. f) DS-GVO is the legal basis.


Disclosure of personal data to third parties and order processors

As a matter of principle, we do not pass on any data to third parties without your consent. If this should nevertheless be the case, then the disclosure takes place on the basis of the previously mentioned legal grounds, e.g. in the case of the disclosure of data to online payment providers for the fulfillment of contracts or due to a court order or because of a legal obligation to hand over the data for the purpose of criminal prosecution, to avert danger or to enforce intellectual property rights.
We also use processors (external service providers, e.g. for web hosting of our websites and databases) to process your data. If data is passed on to the processors as part of a contract processing agreement, this is always done in accordance with Art. 28 DS-GVO. In doing so, we carefully select our processors, regularly monitor them and have been granted a right to issue instructions regarding the data. In addition, the processors must have taken appropriate technical and organizational measures and comply with the data protection regulations according to BDSG n.F. and DS-GVO.

Data transfer to third countries

The adoption of the European General Data Protection Regulation (DS-GVO) has created a uniform basis for data protection in Europe. Your data is therefore predominantly processed by companies to which DS-GVO applies. If, however, processing is carried out by services of third parties outside the European Union or the European Economic Area, these must meet the special requirements of Art. 44 et seq. DS-GVO. This means that the processing takes place on the basis of special guarantees, such as the officially recognized determination by the EU Commission of a level of data protection corresponding to the EU or the observance of officially recognized special contractual obligations, the so-called „standard contractual clauses“.
Insofar as we obtain your express consent to the transfer of data to the USA due to the invalidity of the so-called „Privacy Shield“, pursuant to Article 49 (1) sentence 1 lit. a) DSGVO, we point out in this regard the risk of secret access by US authorities and the use of the data for monitoring purposes, possibly without any legal remedy for EU citizens.

Deletion of data and storage period

Unless expressly stated in this privacy policy, your personal data will be deleted or blocked as soon as you revoke the consent given for processing or the purpose for storing the data no longer applies or the data are no longer required for the purpose, unless their continued storage is necessary for evidence purposes or is contrary to statutory retention obligations. This includes, for example, retention obligations under commercial law for business letters in accordance with Section 257 (1) of the German Commercial Code (HGB) (6 years) and retention obligations under tax law for receipts in accordance with Section 147 (1) of the German Fiscal Code (AO) (10 years). If the prescribed retention period expires, your data will be blocked or deleted, unless the storage is still necessary for the conclusion or fulfillment of a contract.

Existence of automated decision making

We do not use automated decision-making or profiling.

Provision of our website and creation of log files

  1. If you only use our website for informational purposes (i.e. no registration and no other transmission of information), we only collect the personal data that your browser transmits to our server. If you wish to view our website, we collect the following data:

– IP address;
– Internet service provider of the user;
– Date and time of access;
– Browser type;
– Language and browser version;
– Content of the retrieval;
– Time zone;
– Access status/HTTP status code;
– Amount of data;
– Websites from which the request came;
– Operating system.
A storage of this data together with other personal data of you does not take place.

  1. This data is used for the purpose of user-friendly, functional and secure delivery of our website to you with functions and content as well as its optimization and statistical evaluation.
  2. The legal basis for this is our legitimate interest in data processing, which also lies in the above purposes, according to Art. 6 para. 1 p.1 lit. f) DS-GVO.
  3. For security reasons, we store this data in server log files for a storage period of days. After this period, they are automatically deleted, unless we need to keep them for evidence purposes in the event of attacks on the server infrastructure or other legal violations

Contacting us via contact form / e-mail / fax / mail

  1. When contacting us via contact form, fax, mail or e-mail, your information will be processed for the purpose of handling the contact request.
  2. The legal basis for the processing of the data is, if you have given your consent, Art. 6 para. 1 p. 1 lit. a) DS-GVO. The legal basis for the processing of data transmitted in the course of a contact request or e-mail, letter or fax is Art. 6 para. 1 p. 1 lit. f) DS-GVO. The responsible party has a legitimate interest in processing and storing the data in order to be able to answer users‘ inquiries, to preserve evidence for liability reasons and, if necessary, to be able to comply with its statutory retention obligations for business letters. If the contact aims at the conclusion of a contract, the additional legal basis for the processing is Art. 6 para. 1 p. 1 lit. b) DS-GVO.
  3. We may store your information and contact request in our customer relationship management system („CRM system“) or a comparable system.
  4. The data will be deleted as soon as they are no longer required to achieve 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 you has ended. The conversation is ended when it is clear from the circumstances that the matter in question has been conclusively clarified. We store inquiries from users who have an account or contract with us until two years after termination of the contract. In the case of legal archiving obligations, deletion takes place after their expiry: end of commercial law (6 years) and tax law (10 years) retention obligation.
  5. You have the option at any time to revoke your consent to the processing of personal data pursuant to Art. 6 (1) p. 1 lit. a) DS-GVO. If you contact us by e-mail, you can object to the storage of personal data at any time.

Contacting us by telephone

  1. When contacting us by telephone, your telephone number will be processed and temporarily stored or displayed in the RAM / cache of the telephone device / display for the purpose of processing the contact request and its settlement. The storage takes place for liability and security reasons, in order to be able to lead the proof of the call as well as for economic reasons, in order to make a recall possible. In the event of unauthorized advertising calls, we block the phone numbers.
  2. The legal basis for the processing of the telephone number is Art. 6 para. 1 p. 1 lit. f) DS-GVO. If the contact is aimed at concluding a contract, the additional legal basis for processing is Art. 6 (1) lit. b) DS-GVO.
  3. The device cache stores calls for 365 days and successively overwrites or deletes old data; when the device is disposed of, all data is deleted and the memory destroyed if necessary. Blocked phone number are checked annually for the necessity of blocking.
  4. You can prevent the phone number from being displayed by calling with suppressed phone number.


We have integrated the anti-spam function „reCAPTCHA“ from „Google“ (provider: Google Ireland Limited, Reg. No.: 368047, Gordon House, Barrow Street, Dublin 4, Ireland) integrated.
Data category and description of data processing: Usage data (e.g. website accessed, IP). By using „reCAPTCHA“ in our forms, we can determine whether the input was made by a machine (robot) or a human. When using the service, your IP address and possibly other data required for this purpose may be transmitted to Google servers in the USA.

  1. Purpose of processing: Prevention of spam and abuse as well as our economic interest in optimizing our website.
  2. Legal basis: If you have given your consent („opt-in“) for processing of your personal data by means of „reCaptcha“ from the third-party provider, then Art. 6 para. 1 p. 1 lit. a) DS-GVO is the legal basis. In addition, the legal basis is our legitimate interest in data processing in accordance with Art. 6 (1) S.1 lit. f) DS-GVO, which lies in the above purposes.
  3. Data transfer/recipient category: third-party providers in the USA.
    Storage period: until the cookies are deleted by you as the user.
    You can find more information about Google ReCAPTCHA at and in Google’s privacy policy at:

Presence in social media

  1. We maintain profiles or fan pages in social media. When you use and call up our profile in the respective network, the respective data protection information and terms of use of the respective network apply.
  2. Data categories and description of data processing: usage data, contact data, content data, inventory data. Furthermore, user data within social networks is usually processed for market research and advertising purposes. For example, usage profiles can be created based on the usage behavior and resulting interests of the users. The usage profiles can in turn be used, for example, to place advertisements within and outside the networks that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the users‘ computers, in which the usage behavior and interests of the users are stored. Furthermore, data independent of the devices used by the users may also be stored in the usage profiles (especially if the users are members of the respective platforms and are logged in to them). For a detailed presentation of the respective forms of processing and the options to object (opt-out), we refer to the privacy statements and information provided by the operators of the respective networks. In the case of requests for information and the assertion of data subject rights, we also point out that these can be asserted most effectively with the providers. Only the providers have access to the users‘ data and can take appropriate measures and provide information directly. If you still need assistance, then you can contact us.
  3. Purpose of processing: communication with users connected and registered on the social networks; information and advertising for our products, offers and services; external presentation and image cultivation; evaluation and analysis of the users and content of our presences in the social media.
  4. Legal basis: The legal basis for the processing of personal data is our legitimate interest in the above purposes pursuant to Art. 6 (1) p. 1 lit. f) DS-GVO. Insofar as you have given us or the responsible party of the social network consent to the processing of your personal data, the legal basis is Art. 6 para. 1 p. 1 lit. a) in conjunction with. Art. 7 DS-GVO.
  5. Data transfer/recipient category: Social network.
  6. The data protection notices, information options and objection options (opt-out) of the respective networks / service providers can be found here:

– LinkedIn – Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland) – Privacy policy:, Cookie policy and Opt-Out:

Data protection for applications and in the applicant procedure

  1. Applications sent electronically or by mail to the person responsible are processed electronically or manually for the purpose of handling the applicant procedure.
  2. We expressly point out that application documents with „special categories of personal data“ according to Art. 9 DS-GVO (e.g. a photo that gives conclusions about your ethnic origin, religion or marital status), with the exception of a possible severe disability, which you wish to disclose of your own free will, are undesirable. You should submit your application without this data. This will not affect your chances of applying.
  3. The legal basis for the processing is Art. 6 para. 1 p.1 lit. b) DS-GVO as well as § 26 BDSG n.F..
    If, after completion of the application process, an employment relationship is entered into with the applicant, the applicant data will be stored in compliance with the relevant data protection regulations.
  4. If you are not offered a position after completion of the application process, your submitted letter of application including documents will be deleted 6 months after the rejection has been sent, in order to be able to satisfy any claims and obligations to provide evidence in accordance with the AGG.

Rights of the data subject

  1. Objection to or revocation of the processing of your data

Insofar as the processing is based on your consent pursuant to Art. 6 (1) p. 1 lit. a), Art. 7 DS-GVO, you have the right to revoke your consent at any time. This does not affect the lawfulness of the processing carried out on the basis of the consent until the revocation.

Insofar as we base the processing of your personal data on the balance of interests pursuant to Art. 6 (1) p. 1 lit. f) DS-GVO, you may object to the processing. This is the case if the processing is not necessary, in particular, for the performance of a contract with you, which is presented by us in each case in the following description of the functions. When exercising such an objection, we ask you to explain the reasons why we should not process your personal data as we have done. In the event of your justified objection, we will examine the merits of the case and either discontinue or adjust the data processing or show you our compelling legitimate grounds on the basis of which we will continue the processing.

You may object to the processing of your personal data for purposes of advertising and data analysis at any time. You can exercise the right to object free of charge. You can inform us of your advertising objection using the following contact details:

Andreas Streubig-Spiegel
Zwickmöhlen 23 a
22844 Norderstedt Germany
Managing Director Andreas Streubig-Spiegel
E-mail address:

  1. Right to information

You have a right to information about your personal data stored by us in accordance with Art. 15 DS-GVO. This includes, in particular, information about the processing purposes, the category of personal data, the categories of recipients to whom your data has been or will be disclosed, the planned storage period, the origin of your data if it has not been collected directly from you.

  1. Right to rectification

You have a right to have incorrect data corrected or correct data completed in accordance with Art. 16 DS-GVO.

  1. Right to deletion

You have a right to have your data stored by us deleted in accordance with Art. 17 DS-GVO, unless legal or contractual retention periods or other legal obligations or rights to further storage prevent this.

  1. Right to restriction

You have the right to request a restriction in the processing of your personal data if one of the conditions in Art. 18 (1) a) to d) DS-GVO is met:
– If you contest the accuracy of the personal data concerning you for a period enabling the controller to verify the accuracy of the personal data;

– the processing is unlawful and you object to the erasure of the personal data and request instead the restriction of the use of the personal data;

– the controller no longer needs the personal data for the purposes of processing, but you need them for the establishment, exercise or defense of legal claims; or

– if you have objected to the processing pursuant to Article 21 (1) DS-GVO and it is not yet clear whether the legitimate grounds of the controller outweigh your grounds.

  1. Right to data portability
    You have a right to data portability under Article 20 DS-GVO, which means that you can obtain the personal data we hold about you in a structured, commonly used and machine-readable format or request that it be transferred to another controller.
  1. Right to complain
    You have a right to complain to a supervisory authority. As a rule, you can contact the supervisory authority for this purpose, in particular in the Member State of your residence, workplace or the place of the alleged infringement. 

Data security

In order to protect all personal data transmitted to us and to ensure that data protection regulations are complied with by us, as well as by our external service providers, we have taken appropriate technical and organizational security measures. Therefore, among other things, all data between your browser and our server is transmitted encrypted via a secure SSL connection.

Status: 07.08.2021

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