SPINNER GmbH thanks you for visiting this website and for your interest in the products and services of the SPINNER brand. This document informs you in detail about which data SPINNER GmbH captures when you visit our website and how we protect and process this information.
- Controller and data protection officer
- Data capture in connection with the use of our website
- Contact and quotation requests using our form or by email
- Social Media
- Data capture when using our online shop
- Transfer of data to other parties
- Capture and processing of utilization data
- Embedded YouTube videos
- Social plugins
- Google Analytics
- Google Ads
- Google Tag Manager
- Usercentrics Consent Management Platform
- Map services
- Video surveillance at the SPINNER sites in Westerham, Munich and Lauenstein
- Safeguarding of your personal data
- Your rights
1. Controller and data protection officer
Controller in the sense of Art. 4, No. 7 of the General Data Protection Regulation (GDPR) of the European Union:
represented by managing directors Katharina König and Torsten Smyk
80335 Munich, Germany
Phone: +49 89 12601 0
Fax: +49 89 12601 1292
Data protection officer:
TÜV SÜD Sec-IT GmbH
2. Data capture during use of our website
2.1 Data capture
Every time that our website is called, our system―i.e. the webserver―automatically captures information on the computer or other device used to access it.
We collect the following information:
- The browser type and version
- The operating system running on the user’s device
- The user’s Internet service provider
- The user’s IP address
- The date and time at which our website is accessed
- The website, if any, from which the user has linked to our website
2.2 Purpose of use
It is necessary for our system to temporarily save your IP address in order to deliver our website to your computer. For this to work, the IP address must remain stored for the duration of the session.
The information listed above is stored in log files to ensure that our website works as intended. In addition, these data allow us to improve the website and protect our IT systems (e.g. by detecting malicious attacks).
2.3 Legal basis
The legal basis for capturing and temporarily storing these data and log files is a weighing of legitimate interests as per Art. 6, Paragraph 1, Point f of the General Data Protection Regulation of the European Union (GDPR). Our legitimate interest is to make our website available..
2.4 Duration of data storage
The above-mentioned data are erased as soon as they are no longer required for the purposes for which they were captured. Data captured to enable you to access our website are deleted at the end of the current session.
3. Contact and quotation requests received via our form or email
3.1 Data capture
You may contact us by using our contact form or sending a message to the provided email address. In these cases, we store the personal data that you provide together with your question or request.
3.2 Purpose of data processing
These personal data are processed by us solely for the purpose of processing your message.
3.3 Legal basis for data processing
The legal basis for processing data that you communicate to us when submitting a question or request is a weighing of legitimate interests as per Art. 6, Paragraph 1, Point (f) of the GDPR (our legitimate interest is to communicate with external customers and other interested parties), the performance of a precontractual condition, or the fulfillment of a contract as per Art. 6, Paragraph 1, Point (b) of the GDPR.
3.4 Relaying of data to third countries
The SPINNER Group operates sales branches in various regions worldwide. In the case of requests received from outside the European Union, SPINNER reserves the right to relay your data to a regionally responsible sales branch that is geographically closer to you for processing your request or subsequent orders. Requests received from within the European Union are also processed inside the EU.
When data are relayed to third countries, this is done strictly in accordance with legal requirements, e.g.:
- when there is a legitimate interest in locally processing your request or
- when this is required in order to fulfill the contract.
Additional details on relaying data to third countries are provided in the sections on data capture and processing below.
3.5 Duration of data storage
The above-mentioned data are erased as soon as they are no longer required for fulfilling the purpose for which they have been captured. Regarding personal data that are sent to us by email or using the contact form, this is the case when processing of your request has been completed.
4. Social Media
4.1 Data capture
You can contact us using our contact form, the provided email address, or our social media pages. In the case of social media, we store the personal data that you send together with your request.
4.2 Purpose of data processing
These data are processed exclusively to facilitate the processing your request.
4.3 Legal basis for data processing
The legal basis for processing the data you send to use with your request is a weighing of legitimate interests as per Art. 6, Paragraph 1, Point (f) of the GDPR (our legitimate interest is to communicate with customers and interested parties) or the performance of a precontractual measure and/or fulfillment of a contract with you as per Art. 6, Paragraph 1, Point (b) of the GDPR.
4.4 Relaying of data to third countries
Please note that you use these platforms and their functions at your own risk. The company of SPINNER does not actively relay any data from requests in social media to recipients in third countries. We wish to point out, however, that when using social media your data may be processed outside the territory of the European Union. For obtaining detailed information on how the social media providers process data, section 4.5 below contains a list including contact information and links.
4.5 Duration of data storage
The above-mentioned data are erased as soon as they are no longer required for the purpose for which they have been captured. Regarding personal data that are sent to us by email or using the contact form, this is the case when processing of your request has been completed.
For information on processing of your data by other providers, please consult:
- Facebook (operator: Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA) https://de-de.facebook.com/privacy/explanation
- Twitter (operator: Twitter Inc., 795 Folsom St., Suite 600, San Francisco, CA 94107, USA) https://twitter.com/de/privacy
- YouTube (operator: Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA) https://policies.google.com/privacy?hl=de&gl=de
- LinkedIn (operator: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland) https://www.linkedin.com/legal/privacy-policy?trk=homepage-basic_footer-privacy-policy
- Xing (operator: XING SE, Dammtorstrasse 30, 20354 Hamburg, Germany) https://privacy.xing.com/de/datenschutzerklaerung
5. Data capture during use of our online shop
5.1. Data capture
If you would like to use our online shop, you must register as a user. We capture and store user and company data (name, postal address, email address, payment data etc.) that you enter. We also combine certain information, such as prices and price lists applicable to use, payment terms, Incoterms® 2020 or other conditions, with your profile. In all cases, processing of your personal data explicitly takes place on a voluntary basis, i.e. with your consent.
5.2 Data transfer for payment processing
For integrating Wirecard’s services in our online shop, we use the products and services of Computop Wirtschaftsinformatik GmbH, Schwarzenbergstrasse 4, 96050 Bamberg, Germany ("Computop"). We have concluded an order processing agreement with Computop for this purpose.
5.3 Purposes of data processing
We process the personal data captured by us via our online shop exclusively for the following purposes: for checking your profile (commercial customer, internal compliance, if relevant credit rating), for confirming and processing your order and payments, for delivering merchandise while meeting any applicable customs and export requirements, for providing services, for communicating with you, and possibly for analyzing the use of our online shop.
5.4 Legal basis for data processing
The legal basis for processing your personal data is a contract with you as per Art. 6, Paragraph 1, Point (b) of the GDPR and/or a weighing of legitimate interests as per Art. 6, Paragraph 1, Point (f) of the GDPR.
5.5 Duration of data storage
The above-mentioned data are erased as soon as they are no longer required for fulfilling the purpose for which they have been captured. Regarding data captured during registration in order to perform a contract or precontractual measures, this is the case when the data are no longer needed to perform the contract. After concluding a contract, it can also be necessary to store personal data of the other party for complying with contractual or legal obligations (e.g. the requirement to retain documents and information of relevance to taxation). We may store data relevant to invoices for up to 10 years.
6. Relaying of data
Personal data captured via this website are only transferred to third parties or contractors to the required extent. For example, we pass your address data to shipping and delivery companies in order for you to receive ordered merchandise.
6.1 Recipients and categories of recipients of personal data
The recipients of data are:
- Government agencies that are legally entitled to receive data (such as social security bodies and tax authorities)
- In-house departments involved in executing relevant business processes (e.g. accounting, invoicing and IT)
- External contractors involved in the processing or use of personal data in accordance with Arts. 28 ff. of the GDPR
- External contractors hired to perform certain business processes (e.g. shipping companies)
- Companies affiliated with SPINNER (e.g. wholly owned subsidiaries)
- SPINNER sales partners (e.g. distributors)
6.2 Legal basis for transferring data
Your personal data are transferred on the basis of your consent (Art. 6, Paragraph 1, Point (a) of the GDPR), either to fulfill a contract with you (Art. 6, Paragraph 1, Point (b) of the GDPR) or to comply with a legal obligation to which we are subject (Art. 6, Paragraph 1, Point (c) of the GDPR). Any processing of your data by a recipient at our request is based on an order processing agreement with that recipient.
We publish a newsletter to inform you about us and what we offer.
In order to send you the newsletter, we need your email address. When subscribing to the newsletter, you must also give us permission to send it to you. The captured data will only be used to send the newsletter.
The legal basis for data processing in this case is Art. 6, Paragraph 1, Point (a) of the GDPR (by your consent).
Our newsletter is sent via MailChimp. The plugins and functions of MailChimp are an offering of The Rocket Science Group LLC, 675 Ponce de Leon Ave NE, Suite 5000, Atlanta, GA 30308, USA.
After If you subscribe to our newsletter, the data you provide are then transferred to MailChimp and stored there. For relaying personal data to The Rocket Science Group LLC in the USA, The Rocket Science Group LLC has obtained certification under the EU-U.S. “Privacy Shield” data protection framework, which ensures the same standard of data protection in the USA as in the European Union. A current certificate can be viewed here: https://www.privacyshield.gov/list.
MailChimp then sends you an email asking you to confirm your subscription (“double opt-in”). MailChimp uses the Google Analytics tool. You can find details on Google Analytics in section 11 of this document.
You may at any time revoke your consent for us to send you the newspaper, along with the associated capture and storage of data. You can do this using a link in the newsletters or by informing us via any of the contact channels given above.
This website uses both temporary session cookies and permanent cookies. Cookies are small text files that your Internet browser stores locally on your computer. These allow us to recognize you if and when you return to our website. This saves you, for example, the trouble of having to register again and helps us recommend relevant products to you. Cookies are a prerequisite for using the shopping basket in our online shop. If you disable cookies in your browsers, you may not be able to fully take advantage of this website’s functionality.
Name of cookie
|Duration of storage/validity
A session cookie is used to facilitate use of the many services available on this website.
|Until end of session
Sustains the login while you are visiting a page.
|Until end of session
Number of products in list
Remembers the number of products to be shown in list or tile views.
Selected product list view
Remembers whether a customer has chosen the list or tile view.
MyAccount panel cookie
Remembers the navigation settings at the lower left in the customer account section.
|Until end of session
Remembers PDF documents that have been downloaded.
||Deleted within a few seconds of being set following verification
Google Analytics cookie used to distinguish users
|| 2 years
Google Analytics cookie used to distinguish users
|| 24 hours
Used to throttle the Google Analytics request rate
|| 1 minute
Contains a token that can be used to retrieve a client ID from the AMP client ID service. Other possible values indicate opt-out, inflight request, or an error retrieving a client ID from the AMP client ID service.
|| 30 seconds to one year
Contains campaign-related information for the user. When Google Analytics and Google Ads accounts are linked, this cookie is read by Google Ads website conversion tags.
For administering permissions to capture and process data and set cookies
Remembers when the newsletter window should stop displaying
Set by AddToAny for efficiently loading resources and balancing functionality
Consent to cookies that are not required for technical reasons can be viewed and changed at any time online on the platform’s consent management platform (CMP).
9. Capture and processing of utilization data
We capture data on use of this website for statistical purposes, for improving our service, for identifying and diagnosing problems with or misuse of our online offering or telecommunications services and systems, and for marketing purposes. What we actually do with this data is described in greater detail in the following sections.
10. Embedded YouTube videos
To the extent that personal data are processed in connection with using YouTube, this is done on the basis of a weighing of legitimate interests as per Art. 6, Paragraph 1, Point (f) of the GDPR (here our legitimate interest is to improve the design of our website to meet your requirements better) or on the basis of your consent as per Art. 6, Paragraph 1, Point (a) of the GDPR.
. You can also manage your cookie-related settings there.
11. Social plugins
Our website uses social plugins, i.e. plugins of social media of the provider AddToAny.
For better protection of your data when visiting our website, these plugins are not fully integrated. Instead, they are only inserted with the aid of HTML links (the “Shariff solution”). This prevents a connection being made to the servers of a social media network when you open a page of our website. If you click on one of the buttons, a new window opens in your browser and calls a page of the other service provider’s website, on which you can then (possibly after entering your login data) click the “like” or “share” button, for example.
To the extent that personal data are processed when using social plugins, this takes place on the basis of a weighing of legitimate interests as per Art. 6, Paragraph 1, Point f of the GDPR (here our legitimate interest is to improve our website’s design to meet your needs better).
For information on the purpose and scope of data capture and further processing and use of captured data by other providers on their websites and your rights and possibilities for safeguarding your privacy by changing settings, please consult the data privacy policies of AddToAny (https://www.addtoany.com/privacy) and the social media providers concerned:
12. Google Analytics
12.1 Data capture and its purpose
This website uses Google Analytics, a web analysis service provided by Google, Inc. (“Google”). Google Analytics uses “cookies”: text files that are stored on your device and permit analysis of how you use the website. The information on the use of our services generated by these cookies is typically transmitted to and stored by Google on servers in the United States. If IP anonymization is enabled on this website, Google crops the IP addresses of users in countries that belong to the European Union or have signed the EEA Agreements. Only in special cases is a full IP address first sent to a Google server in the USA and then cropped. At our request, Google uses this information to evaluate your use of this website, compile reports on website activity, and provide us with other services related to use of this website and the Internet. The IP address sent by your browser is not mingled with any other data of Google’s. You can prevent cookies from being stored on your device by selecting appropriate browser settings; however, please be advised that if you do this you may not be able to fully take advantage of all of this website’s functions. You can also prevent cookie-generated data pertaining to your use of this website (including your IP address) from being captured and sent to Google for processing by downloading and installing the browser plugin available at this address: http://tools.google.com/dlpage/gaoptout?hl=en. It sets an opt-out cookie that suppresses capture of your data while visiting our website.
12.2 Opting out of Google Analytics
For detailed information on the conditions of use of and protection of data by Google Analytics, please go to https://marketingplatform.google.com/about/analytics/terms/us/ or https://policies.google.com/?hl=en&gl=de. On our website, the code “gat._anonymizeIp()” has been added to Google Analytics to ensure anonymized capture of IP addresses. Please note that if you object to the associated tracking, the opt-out cookie may not have the desired effect. One solution is to install an opt-out browser add-on that is available from Google here.
12.3 Legal basis
To the extent that personal data are processed in connection with the use of Google Analytics, this occurs on the basis of a weighing of legitimate interests as per Art. 6, Paragraph 1, Point f of the GDPR (here our legitimate interest is to improve our website’s design to meet your needs better).
13. Google Ads
13.1 Method and purpose of data capture
To measure the success of ads that we place with Google (“Google Ads”, formerly called “Google Adwords”), we use Google Conversion Tracking, an analysis service of Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland (“Google”). Google Ads places a “conversion cookie” on your computer if you reach our website via a Google ad. These cookies expire after 30 days and cannot be used to personally identify you. They merely register the fact that you have clicked on one of our ads and consequently been redirected to our website. This tells us the total number of users that have clicked on an ad of ours and been routed to our website. We do not receive any information that could be used to personally identify users.
The personal data that Google captures in this way are also stored and processed on servers in the United States. The European Commission has not yet decided that the United States generally provides an adequate level of data protection. However, Google has pledged to comply with the terms of the EU-U.S. Privacy Shield framework agreement regulating transatlantic exchanges of personal data for commercial purposes. More information on this is available at https://policies.google.com/privacy/frameworks?hl=en&gl=de. For more information on data protection at Google, see https://policies.google.com/privacy?gl=de&hl=en.
If you do not wish to participate in this tracking process, you can disable it at https://adssettings.google.com/authenticated. You can also disable cookies for conversion tracking by setting your browser to block cookies of the “googleadservices.com” domain.
13.2 Legal basis
The legal basis for processing your data is Art. 6, Paragraph 1, Point (f) of the GDPR (a weighing of interests based on our legitimate interest in being able to measure and thus also improve the effectiveness of our online advertising).
14.Google Tag Manager
14.1 Method and purpose of data capture
Our website uses the Google Tag Manager of Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland (“Google”). The Google Tag Manager is software that lets us centrally insert and manage short sequences of code (collectively known as “tags” or “markers”) on our website for tracking your activities there, among other things. It allows us to more efficiently manage and update these tags via a user interface without any extra programming work. Google Tag Manager does not itself set any cookies or store any data. It is merely a layer connecting implemented tags and corresponding scripts. Data are passed on to the target systems of implemented tags without being saved. Google received anonymized data from us. However, these data only deal with the use of our Tag Manager and do not include any user information saved by the tags. They exclusively serve the purpose of letting us optimize the processes. Google is an active participant in the EU-U.S. Privacy Shield framework that regulates secure and proper transfer of personal data. More information is available at https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&tid=311162537.
14.2 Legal basis
To the extent that personal data are processed in connection with the use of Google Tag Manager, this occurs on the basis of a weighing of legitimate interests as per Art. 6, Paragraph 1, Point (f) of the GDPR (here our legitimate interest is to improve our website’s design to meet your needs better).
15. Usercentrics Consent Management Platform
15.1 Data capture
We are obliged to obtain each website visitor’s consent for setting cookies that are not required for technical reasons. To do this, we make use of a so-called cookie consent tool from the company of Usercentrics.
When you visit our website, a cookie banner is displayed in which you may make checkmarks to consent to cookies or cookie-based applications. No cookies requiring consent are set on your device unless you consent to them.
So that a consent or revocation of consent can be unambiguously associated with a given user, the following information is recorded and relayed to Usercentrics for storage:
- Device information
- Browser information
- An anonymized IP address
- Opt-in and opt-out data
- Date and time of the visit to our website
15.2 Purpose and relay to additional recipients
15.3 Legal basis
To the extent that cookies are set for technically required data processing for operating our website, this is done on the basis of our legitimate interest in designing our website to meet needs. Any processing of your personal data in connection with providing or revoking your consent takes place on the basis of a legal obligation as per Art. 6, Paragraph 1, Point (c) of the GDPR.
15.4Duration of storage
Consent-related data (on both consent and revocation of consent) are stored for three years.
16. Map services
16.1 Data capture and purpose
16.2 Legal basis
To the extent that personal data are processed in connection with the use of Google Maps, this occurs on the basis of a weighing of legitimate interests as per Art. 6, Paragraph 1, Point f of the GDPR (here our legitimate interest is to improve our website’s design to meet your needs better) or on the basis of your consent in accordance with Art. 6, Paragraph 1, Point a of the GDPR.
17.Video surveillance at the SPINNER sites in Westerham, Munich and Lauenstein
Some parts of our company’s facilities are continuously monitored by video cameras. The monitored areas are clearly designated by unambiguous signs.
17.1 Purposes for which your personal data are processed and the legal basis for this processing
“Personal data” refers to all information relating to an identified or identifiable natural person. In order to carry out video surveillance, we process personal data of yours for the purposes named in the following on the indicated legal grounds: Exercising legitimate interests for the following purposes: to protect property, defend domiciliary rights, ensure plant security, clarifying cases of theft and incidents relevant to security, usingand use recordings as evidence in judicial and extrajudicial proceedings.
The legal basis for video surveillance is Art. 6, Paragraph 1, Point (f) of the GDPR in conjunction with Section 4, Paragraph 1, Nos. 2 and 3 of the German Federal Data Protection Act.
The monitored areas are clearly designated by unambiguous signs. No automated decision-making with profiling takes place on the basis of your personal data.
17.2 Categories of recipients of personal data
We do not provide or grant access to your personal data to any external parties unless this is necessary to fulfill the purposes for which your personal data are processed or we have contracted other parties to perform certain tasks or provide certain services that require access to these personal data or, at leastas a minimum, if the possibility that they may require such access cannot be ruled out. Currently the external recipients of personal data are the following (at the Westerham site): Bayern Corporate Services GmbH, Arnulfstrasse 50, 80335 Munich, Germany.
In addition, your personal data are communicated to government offices or authorities to the extent that we are required to provide such information by law, by order of a government authority, or by a court decision in order to investigate criminal acts perpetrated against us. In such a case, the legal basis for processing your personal data is the prosecution of criminal acts in the sense of Section 4, Paragraph 3 of the German Federal Data Protection Act.
17.3 Relaying data to recipients in third countries or to an international organization
Your personal data will not be relayed to any recipients in third countries or any international organizations.
17.4 Duration of storage of personal data
Your personal data will only be stored for as long as they are required for purposes for which they were captured. Depending on the site, this can be up to 120 hours. Your personal data will only be kept stored for longer than that if we are required to do so by law, by order of an authority, or by a court decision in order to investigate criminal acts. In such a case, the legal basis for processing your personal data is the prosecution of criminal acts pursuant to Section 4, Paragraph 3 of the German Federal Data Protection Act.
18. Protection of your personal data
SPINNER GmbH protects your personal data from unauthorized access, use or publication. For this purpose, SPINNER GmbH takes appropriate technical precautions based on the current state of the art in technology. If you need to enter account or credit card information in order to make payment, this is stored exclusively with the contracted PCI-DSS-certified payment service provider and not with us. However, SPINNER GmbH calls your attention to the fact that data transmission over the Internet (e.g. when communicating by email) may suffer from security issues. It is therefore not possible to guarantee that all of your personal data will be absolutely safe from unauthorized access by third parties.
Apart from this, we strongly advise you to also protect yourself, for example by keeping your passwords secret.
19. Your rights
As a “data subject” in the sense of the GDPR, you have the following rights:
- Right of access as per Art. 15 of the GDPR:You have the right to obtain from the controller confirmation as to whether or not personal data concerning you are being processed and, if this is the case, access to the personal data and other information concerning them.
- Right to rectification as per Art. 16 of the GDPR:You have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning you.
- Right to erasure as per Art. 17 of the GDPR: You have the right to obtain from the controller the erasure of personal data concerning you without undue delay.
- Right to restriction of processing as per Art. 18 of the GDPR: You have the right to obtain from the controller the restriction of processing of personal data concerning you.
- Right to access as per Art. 20 of the GDPR: You have the right to receive from the controller the personal data concerning you that have been processed via our website in a structured, commonly used and machine-readable format.
- Right to withdrawal as per Art. 7, Paragraph 3 of the GDPR: You have the right to non-retroactively withdraw, at any time and free of charge, the consent you that have given under Art. 6, Paragraph 1, Point (a) of the GDPR to process personal data of yours that have been obtained via our website. This will not retroactively affect the lawfulness of any processing of your personal data that has taken place with your consent prior to exercising your right of withdrawal.
- Right to object as per 21 of the GDPR: If data are processed on the basis of Art. 6, Paragraph 1, Point (e) or (f) of the GDPR, you have the right to object at any time against the processing of your personal data for reasons arising from your particular situation.
Exercising your rights to erasure, restriction of processing, objection or withdrawal can prevent you from fully taking advantage of our website.
You can directly exercise any of your above-mentioned rights as a data subject by writing a letter to SPINNER GmbH, Erzgiessereistrasse 33, 80335 Munich, Germany or sending an email to . We will then immediately confirm in writing that you have done so and comply with your wishes. It is not sufficient to notify us by phone.
- The right to lodge a complaint with a supervisory authority in accordance with Art. 77 of the GDPR: if you as an affected individual consider that the processing of personal data relating to you via our website violates the GDPR, you have the right to lodge a complaint with the responsible supervisory authority, in particular in the EU member state of your habitual residence, place of work, or place of the alleged infringement.
Responsible supervisory authority in Bavaria: Bayerisches Landesamt für Datenschutzaufsicht, Promenade 27, 91522 Ansbach, Germany, phone: +49 (0) 981 18 00 93-0, fax: +49 (0) 981 18 00 93-800, email: poststelle(at)lda.bayern(dot)de.
Please note that these rights only apply if certain other legal prerequisites are met.
This data protection information reflects the situation as of June 2020.