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Privacy Statement

1.    Collection, storage and use of personal information

a) When you visit our web site

When you visit us online at www.spigraph.com or any other country specific Spigraph page the browser used automatically sends information to our web site server. This information is stored temporarily in a log file. The following information will be collected without your intervention and stored until automated deletion:

  • the IP address of the visiting computer,
  • date and time of access,
  • name and URL of the files requested,
  • web site from which access is made (referrer URL),
  • browser used and, if necessary, the operating system of your computer as well as the name of your access provider.


The data mentioned is processed by us for the following purposes:

  • Ensuring a smooth connection to the web site,
  • Ensuring comfortable use of our web site,
  • Evaluation of system security and stability as well as for
  • further administrative purposes.


The legal basis for data processing is Art. 6 para. 1 sentence 1f EUDPR. Our legitimate interest follows from the data collection purposes listed above. In no case will we use the collected data for the purpose of drawing conclusions about you.

We also use cookies when you visit us online. Further details can be found under 4 and 5 of this privacy policy.


b) When subscribing to our newsletter

In so far as you have explicitly given your consent, pursuant to Art. 6(1)(1)(a) GDPR, we use your e-mail address to send you our newsletter regularly. Giving an e-mail address is sufficient for receiving the newsletter.

It is possible to unsubscribe at any time, for example via a link at the end of each newsletter. Alternatively, you can certainly also send your request to unsubscribe to privacy@spigraph.com by e-mail at any time.


c) When using our contact form

We offer you the opportunity to contact us via a form provided on the web site for any questions you may have. You must provide a valid email address, your first name and last name of the recipient and the country so that we know who the request came from, who the request is for and how to answer it. Further information can be provided voluntarily.

Data processing for the purpose of contacting us is in accordance with Art. 6 para. 1 sent. 1a EUDPR on the basis of the consent, which you grant voluntarily on sending the request.

The personal data collected by us for the use of the contact form will be deleted automatically after completion of the request made by you.

2.    The passing on of data

Your personal data is not transmitted to third parties for purposes other than the purposes listed below.

We only pass on your personal data to third parties if:

  • You have granted your express consent to the latter pursuant to Art. 6(1)(1)(a) GDPR;
  • pursuant to Art. 6(1)(1)(f ) GDPR, it is necessary to pass it on in order to assert, exercise or defend legal claims and no reason exists to assume that you have an overwhelming interest, worthy of protection, in your data not being passed on;
  • in the event that a statutory obligation to pass on the data exists pursuant to Art. 6(1)(1)(c) GDPR; and
  • this is statutorily admissible and, under Art. 6(1)(1)(b) GDPR, is necessary in order to handle contractual relations with you.

3.    Analysis tools / tracking tools

The tracking steps listed by us below and deployed by us are carried out based on Art. 6(1)(1)(f) GDPR. With the tracking measures deployed, we wish to ensure that our website is designed in line with our customers’ needs and also ensure ongoing optimisation of it. Secondly, we deploy the tracking steps in order to record statistics on the use of our website, and for the purpose of evaluating your use of our website in order to optimise our services for you. These interests are to be deemed justified in the sense of the foregoing provision.

The respective data processing purposes and data categories can be inferred from the corresponding tracking tools.


a) Google Analytics

In order to design our web pages in line with customer requirements, and to ensure that our web pages are optimised on an ongoing basis, we use Google Analytics, a web analysis service of Google Inc. ( https://www.google.com/intl/com/about/ ) (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; hereinafter referred to as “Google”). This involves pseudonymised usage profiles being created, and cookies deployed (see Clause 4). The information generated by the cookie on your use of this website, such as

  • browser type/version;
  • operating system used;
  • referring URL (the page visited previously);
  • host name of the accessing PC (IP address);
  • time of the server query.


will be transmitted to a server of Google in the USA and stored there. The information will be used to evaluate use of the website, compile reports on the website activities, and provide further services associated with the use of the website and the Internet for market research purposes and to design these web pages in line with user requirements. This information may also be transmitted to third parties, in so far as such is required by law or if third parties process such data by order. Your IP address will never be merged with other data of Google. The IP addresses are anonymised, making it impossible to identify them (IP masking).

You can prevent the installation of cookies by setting your browser accordingly, however we would like to point out that, in that case, you may not be able to use all the functions of this website in their entirety.

You may, moreover, prevent the data generated by the cookie which relates to your use of the website (incl. your IP address) from being recorded, as well as the processing of such data by Google, by downloading and installing a browser add-on available at the following link ( https://tools.google.com/dlpage/gaoptout?hl=en ).

As an alternative to the browser add-on, in particular in the case of browsers on mobile terminals, you may additionally prevent your data from being recorded by Google Analytics by clicking on this link. An opt-out cookie is placed, which prevents your data from being recorded when visiting this website in future. The opt-out cookie only takes effect in this browser, and only when visiting our website, and will be stored on your device. If you delete the cookies in this browser, you need to re-set the opt-out cookie.

You can find further information on data privacy in connection with Google Analytics, for instance in the Google Analytics Helpat the following link: ( https://support.google.com/analytics/answer/6004245?hl=en ).

4.    Social media plug-ins

Based on Art. 6(1)(1)(f) GDPR, we set social plug-ins on our website of the social networks Facebook, Twitter, Google+, LinkedIn and YouTube in order to make our company more well known in this way. Cookies are also used in accordance with section 6 of this declaration. The commercial purpose behind that is to be deemed a justified interest within the meaning of the GDPR. The responsibility for the operation compliant with data protection is to be guaranteed by their respective providers. The integration of these plug-ins by us is done by a so-called two-click method to protect visitors to our website in the best possible way.

a) Facebook

Social media plug-ins of Facebook are deployed on our website, in order to design the use of it in a more personal way. For this we use the "LIKE" or "SHARE" button. It is an offer from Facebook.

Whenever you access a page on our website that contains one of these plug-ins, your browser establishes a direct connection to Facebook’s servers. The content of the plug-in is transmitted by Facebook directly to your browser and integrated by the latter into the web page. Integrating the plug-in sends information to Facebook indicating that you have accessed the corresponding page on our website, even if you do not have a Facebook account or are not logged into Facebook just now. Such information (including your IP address) is transmitted directly by your browser to one of Facebook’s servers in the USA where it is saved.

When you visit our website and are logged into Facebook at the same time, this enables to Facebook to link information about your visit to your Facebook account. Whenever you interact with the plug-ins, for example by pressing the “LIKE” or “SHARE” button, the corresponding information is likewise transmitted directly to one of Facebook’s servers, and stored there. In addition, the information is published on Facebook, and shown to your Facebook friends.

Facebook may use this information for the purposes of advertising, market research and designing the Facebook pages in line with users’ requirements. Usage, interest and relationship profiles are created by Facebook for this purpose, e.g. in order to evaluate your use of our website in regard to the advertisements shown to you on Facebook, to inform other Facebook users about your activities on our website, and to provide further services connected with the use of Facebook.

If you would prefer Facebook not to allocate the data gathered via our website to your Facebook account, you need to log out of Facebook prior to visiting our website.

Please infer the purpose and scope of data collection and the further processing and use of the data by Facebook, as well as your rights in this respect and the configuration options for protecting your private sphere from the data privacy policiesof Facebook at the following link https://en-gb.facebook.com/about/privacy/

b) Twitter

Plug-ins of the short message network of Twitter Inc. (hereinafter referred to as “Twitter”) are integrated into our website. You can recognise the Twitter plug-ins (“Tweet button”) by the Twitter logo on our website. You can find an overview of Tweet buttons here ( https://about.twitter.com/resources/buttons ).

When you visit a page of our website containing such a plug-in, a direct connection is established between your web browser and the Twitter server. Twitter thereby receives the information that you have visited our website with your IP address. If you click on the Twitter “Tweet button” while you are logged into your Twitter account, you can link the content of our pages to your Twitter profile. Twitter can thereby allocate the visit to our pages to your user account. We are pointing out that we, as the provider of the pages, are not made aware of the content of the data transmitted or its use by Twitter.

If you do not wish Twitter to be able to allocate your visit to our pages to your Twitter account, please log out of your Twitter user account.

You can obtain further information on the latter in Twitter’s privacy policy at the following link

( https://twitter.com/privacy ).

c) Google+

This website uses the so-called “G +1” button of the Google Plus social network, which is operated by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States (“Google”).

The button can be recognized by the “G+1” symbol. If you are registered with Google Plus, you can use the “G +1” button to express your interest in our website and to share its contents on Google Plus. In this case, Google stores both the information which you have given a “G +1” for one of our contents, and also information on the site which you viewed while doing so. Your “G +1” may be displayed with your name (and possibly a photo if available) on Google Plus in additional Google services, such as Google search or your Google profile.

Please refer to Google’s data-protection information for the purpose and scope of the data recording and the further processing and usage of the data by Google and your rights and settings options to protect your privacy in this regard https://www.google.com/intl/de/policies/privacy/

d) LinkedIn

We have integrated components of the LinkedIn Corporation on this website. LinkedIn is a web-based social network that enables users with existing business contacts to connect and to make new business contacts. Over 400 million registered people in more than 200 countries use LinkedIn. Thus, LinkedIn is currently the largest platform for business contacts and one of the most visited websites in the world.

The operating company of LinkedIn is LinkedIn Corporation, 2029 Stierlin Court Mountain View, CA 94043, United States. For privacy matters outside of the United States LinkedIn Ireland, Privacy Policy Issues, Wilton Plaza, Wilton Place, Dublin 2, Ireland, is responsible.

With each call-up to one of the individual pages of this Internet site, which is operated by the controller and on which a LinkedIn component (LinkedIn plug-in) was integrated, the Internet browser on the information technology system of the data subject is automatically prompted to the download of a display of the corresponding LinkedIn component of LinkedIn. Further information about the LinkedIn plug-in may be accessed under https://developer.linkedin.com/plugins. During the course of this technical procedure, LinkedIn gains knowledge of what specific sub-page of our website was visited by the data subject.

If the data subject is logged in at the same time on LinkedIn, LinkedIn detects with every call-up to our website by the data subject—and for the entire duration of their stay on our Internet site—which specific sub-page of our Internet page was visited by the data subject. This information is collected through the LinkedIn component and associated with the respective LinkedIn account of the data subject. If the data subject clicks on one of the LinkedIn buttons integrated on our website, then LinkedIn assigns this information to the personal LinkedIn user account of the data subject and stores the personal data.

LinkedIn receives information via the LinkedIn component that the data subject has visited our website, provided that the data subject is logged in at LinkedIn at the time of the call-up to our website. This occurs regardless of whether the person clicks on the LinkedIn button or not. If such a transmission of information to LinkedIn is not desirable for the data subject, then he or she may prevent this by logging off from their LinkedIn account before a call-up to our website is made.

LinkedIn provides under https://www.linkedin.com/psettings/guest-controls the possibility to unsubscribe from e-mail messages, SMS messages and targeted ads, as well as the ability to manage ad settings. LinkedIn also uses affiliates such as Eire, Google Analytics, BlueKai, DoubleClick, Nielsen, Comscore, Eloqua, and Lotame. The setting of such cookies may be denied under https://www.linkedin.com/legal/cookie-policy . The applicable privacy policy for LinkedIn is available under https://www.linkedin.com/legal/privacy-policy . The LinkedIn Cookie Policy is available under https://www.linkedin.com/legal/cookie-policy .

e) YouTube

We have integrated components of YouTube. YouTube is an Internet video portal that enables video publishers to set video clips and other users free of charge, which also provides free viewing, review and commenting on them. YouTube allows you to publish all kinds of videos, so you can access both full movies and TV broadcasts, as well as music videos, trailers, and videos made by users via the Internet portal.

The operating company of YouTube is YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, United States. The YouTube, LLC is a subsidiary of Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States.

With each call-up to one of the individual pages of this Internet site, which is operated by the controller and on which a YouTube component (YouTube video) was integrated, the Internet browser on the information technology system of the data subject is automatically prompted to download a display of the corresponding YouTube component. Further information about YouTube may be obtained under https://www.youtube.com/yt/about/ . During the course of this technical procedure, YouTube and Google gain knowledge of what specific sub-page of our website was visited by the data subject.

If the data subject is logged in on YouTube, YouTube recognizes with each call-up to a sub-page that contains a YouTube video, which specific sub-page of our Internet site was visited by the data subject. This information is collected by YouTube and Google and assigned to the respective YouTube account of the data subject.

YouTube and Google will receive information through the YouTube component that the data subject has visited our website, if the data subject at the time of the call to our website is logged in on YouTube; this occurs regardless of whether the person clicks on a YouTube video or not. If such a transmission of this information to YouTube and Google is not desirable for the data subject, the delivery may be prevented if the data subject logs off from their own YouTube account before a call-up to our website is made.

YouTube’s data protection provisions, available at https://www.google.com/intl/en/policies/privacy/ , provide information about the collection, processing and use of personal data by YouTube and Google.

5.    Cookies

We use cookies on our web site. These are small files that your browser automatically creates and that are stored on your device (laptop, tablet, smartphone, etc.) when you visit our site. Cookies do not harm your device, do not contain viruses, Trojans or other malicious software.

Information relating to each terminal used is stored in the cookie. However, this does not mean that we are directly aware of your identity.

Cookies are used to guarantee use and security of our web site and to make browsing our site more comfortable for you. For instance, we set session cookies to recognise that you have already visited individual pages of our website. They are automatically deleted once your visit to our website has ended.

In order to optimise usability, we also set temporary cookies, that are stored on your terminal for a certain pre-defined period of time. If you visit our website again, to make use of our services, it is automatically recognised that you have already visited us, as well as what data you entered and settings you selected, so that you do not have to enter them all over again.

Secondly, we set cookies to record statistics on the use of our website, and for the purpose of evaluating your use of our website in order to optimise our services for you (see Clause 5). These cookies enable us to automatically recognise that you have already previously visited us when you visit our website again. These cookies are automatically deleted after a certain pre-defined period of time.

The data processed by the cookies is required for the purposes mentioned, in order to preserve our justified interests, as well as those of third parties pursuant to Art. 6(1)(1)(f) GDPR.

Most browsers accept cookies automatically. However, you can configure your browser so that no cookies are stored on your computer. A notification banner will appear before a new cookie is created. Disabling cookies completely may mean that you cannot use all of the features of our web site.

6.    Your rights

You have the right:

  • pursuant to Art. 15 EUDPR to request information about your personal data that is processed by us. In particular, you can request information on the processing purposes, the category of personal data, the categories of recipients to whom your data has been disclosed, the planned retention period, the right of rectification, deletion, limitation of processing or opposition, the existence of a the right to complain, the source of your data, if not collected by us, and the existence of automated decision-making, including profiling and, where appropriate, meaningful information about the details thereof;
  • pursuant to Art. 16 EUDPR, to demand immediate correction or completion of incorrect or incomplete personal data stored by us;
  • in accordance with Art. 17 EUDPR, to demand the deletion of your personal data stored by us, except where processing is required for the exercise of the right to freedom of expression and information, for the fulfilment of a legal obligation, for reasons of public interest or for the assertion, exercise or defence of legal claims;
  • to demand the restriction of the processing of your personal data in accordance with Art. 18 EUDPR, insofar as the accuracy of the data is disputed by you, the processing is unlawful, but you reject its deletion; we no longer need the data, but you need it for asserting, exercising or defending legal claims or you have objected to processing in accordance with Art. 21 GDPR;
  • pursuant to Art. 20 GDPR to obtain the personal data that you provided to us in a structured, usual and machine-readable format or to request the that it be sent to another responsible person;
  • pursuant to Art. 7 para. 3 EUDPR to revoke your consent to us at any time. As a result, we are not allowed to continue processing data based on this consent in the future; and
  • pursuant to Art. 77 EUDPR to complain to a supervisory authority. As a rule, you can contact the supervisory authority of your usual place of residence or work or that of our registered address.

7.    Right to object

If your personal data is processed on the basis of legitimate interests in accordance with Art. 6 para. 1 sentence 1f GDPR, you have the right to file an objection against the processing of your personal data in accordance with Art. 21 GDPR, provided there are reasons for this arising from your particular situation.

If you would like to exercise your right of revocation or objection, please send an email to privacy@spigraph.com .

8.    Data security

Within the context of the visit to our website, we use SSL (Secure Socket Layer) procedures in conjunction with the highest respective encryption level that is supported by your browser. This would generally be 256-bit encryption. Should your browser not support 256-bit encryption, we instead resort to 128-bit v3 technology. You can recognise whether an individual page of our website is transferred encrypted by the key or lock symbol being displayed in the lower status bar of your browser as closed.

We also take appropriate technical and organisational security measures to protect your data against accidental or intentional manipulation, partial or total loss, destruction or against unauthorised access by third parties. Our security measures are continuously improved in line with technological developments.

9. Topicality and amendment of this data privacy statement

This privacy statement is currently valid and was last updated in May 2018.

Due to the evolution of our web site and offers, or due to changed legal or regulatory requirements, it may be necessary to make changes to this privacy policy. The current privacy policy can be viewed at any time on our website at http://spigraph.com/Legal-Notice/Privacy-Statement and printed out.