Imprint

Information pursuant to §5 of the German Telemedia Act (TMG)

Christian Spoo
Pfarrer-Erich-Fuchs-Ring 12
41812 Erkelenz

Contact

E-Mail: christian@fam-spoo.de

Privacy policy

Preamble

With the following privacy policy, we would like to inform you about the types of personal data (hereinafter also referred to as “data”) we process, for what purposes, and to what extent. The privacy policy applies to all processing of personal data carried out by us, both in the context of providing our services and, in particular, on our websites, in mobile applications, and within external online presences, such as our social media profiles (hereinafter collectively referred to as “online offering”).

The terms used are not gender-specific.

As of: December 24, 2025

Responsible person

Christian Spoo
Pfarrer-Erich-Fuchs-Ring 12
41812 Erkelenz, Germany

Authorized representatives: Christian Spoo

Email address: mail@christian-spoo.info

Overview of processing

The following overview summarizes the types of data processed and the purposes for which they are processed, and refers to the data subjects.

Types of data processed

  • Inventory data.
  • Contact details.
  • Content data.
  • Usage data.
  • Meta, communication, and procedural data.
  • Log data.

Categories of data subjects

  • Users.

Purposes of processing

  • Communication.
  • Security measures.
  • Organizational and administrative procedures.
  • Feedback.
  • Provision of our online offering and user-friendliness.
  • Information technology infrastructure.
  • Public relations.

Relevant legal bases under the GDPR: Below you will find an overview of the legal bases under the GDPR on which we process personal data. Please note that, in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. If more specific legal bases are relevant in individual cases, we will inform you of this in the privacy policy.

Legitimate interests (Art. 6(1)(f) GDPR) - processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

National data protection regulations in Germany: In addition to the data protection regulations of the GDPR, national regulations on data protection apply in Germany. These include, in particular, the Act on the Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act – BDSG). The BDSG contains, in particular, special regulations on the right to information, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes and transfer, as well as automated decision-making in individual cases, including profiling. Furthermore, state data protection laws of the individual federal states may also apply.

Security measures

In accordance with legal requirements, we take appropriate technical and organizational measures to ensure a level of protection appropriate to the risk, taking into account the state of the art, implementation costs, and the nature, scope, circumstances, and purposes of the processing, as well as the varying likelihood and severity of threats to the rights and freedoms of natural persons.

These measures include, in particular, ensuring the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data as well as access, input, transfer, availability, and separation. Furthermore, we have established procedures to ensure that the rights of data subjects are exercised, data is deleted, and responses are made to threats to data. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software, and procedures in accordance with the principle of data protection, through technology design and data protection-friendly default settings.

Securing online connections with TLS/SSL encryption technology (HTTPS): We use TLS/SSL encryption technology to protect user data transmitted via our online services from unauthorized access. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the Internet. These technologies encrypt the information transmitted between the website or app and the user’s browser (or between two servers), protecting the data from unauthorized access. TLS, as the more advanced and secure version of SSL, ensures that all data transmissions meet the highest security standards. When a website is secured by an SSL/TLS certificate, this is indicated by the display of HTTPS in the URL. This serves as an indicator to users that their data is being transmitted securely and encrypted.

International data transfers

Data processing in third countries: If we transfer data to a third country (i.e., outside the European Union (EU) or the European Economic Area (EEA)) or if this occurs in the context of using third-party services or disclosing or transferring data to other persons, agencies, or companies (which can be identified by the postal address of the respective provider or if the privacy policy expressly refers to the transfer of data to third countries), this is always done in accordance with legal requirements.

For data transfers to the USA, we primarily rely on the Data Privacy Framework (DPF), which was recognized as a secure legal framework by an adequacy decision of the EU Commission on July 10, 2023. In addition, we have concluded standard contractual clauses with the respective providers that comply with the requirements of the EU Commission and establish contractual obligations to protect your data.

This dual safeguard ensures comprehensive protection for your data: the DPF forms the primary level of protection, while the standard contractual clauses serve as additional security. Should changes arise within the framework of the DPF, the standard contractual clauses serve as a reliable fallback option. This ensures that your data remains adequately protected even in the event of political or legal changes.

We will inform you whether individual service providers are certified under the DPF and whether standard contractual clauses are in place. For more information on the DPF and a list of certified companies, please visit the U.S. Department of Commerce website at https://www.dataprivacyframework.gov/ (in English language).

Appropriate security measures apply to data transfers to other third countries, in particular standard contractual clauses, explicit consent, or transfers required by law. Information on third-country transfers and applicable adequacy decisions can be found in the information provided by the EU Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en?prefLang=de.

General information on data storage and deletion

We delete personal data that we process in accordance with legal requirements as soon as the underlying consent is revoked or there is no further legal basis for processing. This applies to cases in which the original purpose of processing no longer applies or the data is no longer required. Exceptions to this rule exist if legal obligations or special interests require longer storage or archiving of the data.

In particular, data that must be retained for commercial or tax reasons or whose storage is necessary for legal prosecution or to protect the rights of other natural or legal persons must be archived accordingly.

Our data protection information contains additional information on the storage and deletion of data that applies specifically to certain processing procedures.

If there are several specifications regarding the retention period or deletion deadlines for a piece of data, the longest period shall always apply. We process data that is no longer required for its original purpose but is retained due to legal requirements or other reasons exclusively for the reasons that justify its retention.

Storage and deletion of data: The following general periods apply to storage and archiving under German law:

  • 10 years - Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheets, and the work instructions and other organizational documents necessary for their understanding (§ 147 (1) No. 1 in conjunction with (3) AO, § 14b (1) UStG, § 257 (1) No. 1 in conjunction with (4) HGB).
  • 8 years - Accounting documents, such as invoices and expense receipts (§ 147 (1) No. 4 and 4a in conjunction with (3) sentence 1 AO and § 257 (1) No. 4 in conjunction with (4) HGB).
  • 6 years – Other business documents: commercial or business letters received, copies of commercial or business letters sent, other documents relevant for taxation purposes, e.g., hourly wage slips, operating statements, calculation documents, price tags, but also payroll documents, insofar as they are not already accounting documents, and cash register receipts (§ 147 (1) No. 2, 3, 5 in conjunction with (3) AO, § 257 (1) No. 2 and 3 in conjunction with (4) HGB).
  • 3 years - Data required to consider potential warranty and damage claims or similar contractual claims and rights, as well as to process related inquiries, based on previous business experience and customary industry practices, will be stored for the duration of the regular statutory limitation period of three years (§§ 195, 199 BGB).

Start of the period at the end of the year: If a period does not expressly begin on a specific date and lasts at least one year, it automatically begins at the end of the calendar year in which the event triggering the period occurred. In the case of ongoing contractual relationships in which data is stored, the event triggering the period is the date on which the termination or other termination of the legal relationship takes effect.

Rights of data subjects

Rights of data subjects under the GDPR: As a data subject, you have various rights under the GDPR, which arise in particular from Articles 15 to 21 GDPR:

  • Right to object: You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Article 6(1)(e) or (f) GDPR; this also applies to profiling based on these provisions. If the personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling insofar as it is related to such direct marketing.
  • Right to withdraw consent: You have the right to withdraw your consent at any time.
  • Right to information: You have the right to request confirmation as to whether data concerning you is being processed and to obtain information about this data, as well as further information and a copy of the data in accordance with the statutory provisions.
  • Right to rectification: In accordance with the statutory provisions, you have the right to request the completion of data concerning you or the rectification of inaccurate data concerning you.
  • Right to erasure and restriction of processing: In accordance with legal requirements, you have the right to request that data concerning you be erased immediately or, alternatively, in accordance with legal requirements, to request a restriction on the processing of the data.
  • Right to data portability: You have the right to receive data concerning you that you have provided to us in a structured, commonly used, and machine-readable format in accordance with legal requirements, or to request that it be transferred to another controller.
  • Complaint to supervisory authority: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, your place of work, or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the provisions of the GDPR.

Provision of online services and web hosting

We process user data in order to provide them with our online services. For this purpose, we process the user’s IP address, which is necessary to transmit the content and functions of our online services to the user’s browser or device.

  • Types of data processed: Usage data (e.g., page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); Meta, communication, and process data (e.g., IP addresses, time stamps, identification numbers, persons involved). Log data (e.g., log files relating to logins or the retrieval of data or access times).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing: Provision of our online offering and user-friendliness; information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)). Security measures.
  • Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion.”
  • Legal basis: Legitimate interests (Art. 6(1)(f) GDPR).

Further information on processing operations, procedures, and services:

  • Provision of online services on rented storage space: To provide our online services, we use storage space, computing capacity, and software that we rent or otherwise obtain from a corresponding server provider (also known as a “web host”); legal basis: legitimate interests (Art. 6(1)(f) GDPR).
  • Collection of access data and log files: Access to our online offering is logged in the form of so-called “server log files.” Server log files may include the address and name of the websites and files accessed, the date and time of access, the amount of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider. The server log files can be used for security purposes, e.g. to prevent server overload (especially in the case of malicious attacks, known as DDoS attacks), and to ensure server utilization and stability; legal basis: legitimate interests (Art. 6 (1) (f) GDPR). Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data that must be retained for evidentiary purposes is excluded from deletion until the respective incident has been finally clarified.
  • Hetzner: Services in the field of providing information technology infrastructure and related services (e.g., storage space and/or computing capacity); Service provider: Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.hetzner.com; Privacy policy: https://www.hetzner.com/de/rechtliches/datenschutz. Data processing agreement: https://docs.hetzner.com/de/general/general-terms-and-conditions/data-privacy-faq/.

Use of cookies

The term “cookies” refers to functions that store and read information on users’ end devices. Cookies can also be used for various purposes, such as to ensure the functionality, security, and convenience of online offerings and to analyze visitor traffic. We use cookies in accordance with legal requirements. To this end, we obtain the consent of users in advance if necessary. If consent is not necessary, we rely on our legitimate interests. This applies if the storage and retrieval of information is essential in order to provide expressly requested content and functions. This includes, for example, the storage of settings and ensuring the functionality and security of our online offering. Consent can be revoked at any time. We provide clear information about their scope and which cookies are used.

Information on the legal basis for data protection: Whether we process personal data using cookies depends on consent. If consent has been given, it serves as the legal basis. Without consent, we rely on our legitimate interests, which are explained above in this section and in the context of the respective services and procedures.

Storage period: With regard to the storage period, a distinction is made between the following types of cookies:

  • Temporary cookies (also known as session cookies): Temporary cookies are deleted at the latest after a user leaves an online offering and closes their device (e.g., browser or mobile application).
  • Permanent cookies: Permanent cookies remain stored even after the device is closed. This allows, for example, the log-in status to be saved and preferred content to be displayed directly when the user visits a website again. The user data collected with the help of cookies can also be used to measure reach. Unless we provide users with explicit information about the type and storage duration of cookies (e.g., when obtaining consent), they should assume that these are permanent and that the storage period can be up to two years.

General information on revocation and objection (opt-out): Users can revoke their consent at any time and also object to the processing in accordance with the legal requirements, including by means of their browser’s privacy settings.

  • Types of data processed: Meta, communication, and procedural data (e.g., IP addresses, time stamps, identification numbers, persons involved).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Legal basis: Legitimate interests (Art. 6(1)(f) GDPR).

Blogs and publication media

We use blogs or similar means of online communication and publication (hereinafter referred to as “publication media”). Reader data is only processed for the purposes of the publication media to the extent necessary for its presentation and communication between authors and readers or for security reasons. For further information, please refer to the information on the processing of visitors to our publication media in this privacy policy.

  • Types of data processed: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); contact data (e.g., postal and email addresses or telephone numbers); content data (e.g., textual or pictorial messages and posts, as well as information relating to them, such as details of authorship or time of creation); Usage data (e.g., page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Meta, communication, and procedural data (e.g., IP addresses, time stamps, identification numbers, persons involved).
  • Affected persons: Users (e.g., website visitors, users of online services).
  • Purposes of processing: Feedback (e.g., collecting feedback via online form); provision of our online offering and user-friendliness; security measures. Organizational and administrative procedures.
  • Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion.”
  • Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR).

Further information on processing operations, procedures, and services:

Comments and posts: If users leave comments or other posts, their IP addresses may be stored on the basis of our legitimate interests. This is for our security in case someone leaves illegal content in comments and posts (insults, prohibited political propaganda, etc.). In this case, we ourselves may be prosecuted for the comment or post and are therefore interested in the identity of the author.
Furthermore, we reserve the right to process user data for the purpose of spam detection on the basis of our legitimate interests.
On the same legal basis, we reserve the right to store users’ IP addresses for the duration of surveys and to use cookies to prevent multiple votes.
The personal information provided in comments and posts, any contact and website information, as well as the content information, will be stored by us permanently until the user objects; legal basis: legitimate interests (Art. 6 (1) (f) GDPR).

Presence on social networks (social media)

We maintain an online presence on social networks and process user data in this context in order to communicate with users active there or to provide information about us.

We would like to point out that user data may be processed outside the European Union. This may pose risks for users, as it could, for example, make it more difficult to enforce user rights.

Furthermore, user data within social networks is generally processed for market research and advertising purposes. For example, usage profiles can be created based on the usage behavior and resulting interests of users. The latter may in turn be used to place advertisements within and outside the networks that are presumed to correspond to the interests of the users. For this reason, cookies are usually stored on users’ computers, in which their usage behavior and interests are stored. In addition, data can also be stored in the usage profiles independently of the devices used by the users (especially if they are members of the respective platforms and are logged in there).

For a detailed description of the respective forms of processing and the options for objection (opt-out), please refer to the privacy policies 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 would also like to point out that these can be most effectively asserted with the providers. Only the latter have access to the user data and can take appropriate measures and provide information directly. However, if you still need help, you can contact us.

  • Types of data processed: Contact details (e.g., postal and email addresses or telephone numbers); Content data (e.g., text or image messages and posts, as well as information relating to them, such as details of authorship or time of creation). Usage data (e.g., page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions).
  • Affected persons: Users (e.g., website visitors, users of online services).
  • Purposes of processing: Communication; feedback (e.g., collecting feedback via online form). Public relations.
  • Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion.”
  • Legal basis: Legitimate interests (Art. 6(1)(f) GDPR).

Further information on processing operations, procedures, and services:

  • Instagram: Social network that allows users to share photos and videos, comment on and favorite posts, send messages, and subscribe to profiles and pages; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.instagram.com; Privacy policy: https://privacycenter.instagram.com/policy/. Basis for third country transfers: Data Privacy Framework (DPF).
  • LinkedIn: Social network - Together with LinkedIn Ireland Unlimited Company, we are responsible for the collection (but not the further processing) of visitor data used to generate “Page Insights” (statistics) for our LinkedIn profiles. This data includes information about the types of content users view or interact with, as well as the actions they take. In addition, details about the devices used are collected, such as IP addresses, operating system, browser type, language settings, and cookie data, as well as information from user profiles, such as job title, country, industry, hierarchy level, company size, and employment status. Information on LinkedIn’s privacy policy regarding the processing of user data can be found in LinkedIn’s privacy policy: https://www.linkedin.com/legal/privacy-policy.
    We have entered into a special agreement with LinkedIn Ireland (“Page Insights Joint Controller Addendum,” https://legal.linkedin.com/pages-joint-controller-addendum), which specifically regulates the security measures LinkedIn must observe and in which LinkedIn has agreed to fulfill the rights of data subjects (i.e., users can, for example, submit requests for information or deletion directly to LinkedIn). The rights of users (in particular the right to information, deletion, objection, and complaint to the competent supervisory authority) are not restricted by the agreements with LinkedIn. Joint responsibility is limited to the collection and transfer of data to LinkedIn Ireland Unlimited Company, a company based in the EU. Further processing of the data is the sole responsibility of LinkedIn Ireland Unlimited Company, in particular with regard to the transfer of data to the parent company LinkedIn Corporation in the USA; service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; legal basis: legitimate interests (Art. 6 (1) (f) GDPR); website: https://www.linkedin.com; privacy policy: https://www.linkedin.com/legal/privacy-policy; Basis for third country transfers: Data Privacy Framework (DPF), https://legal.linkedin.com/dpa. Opt-out option: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
  • X: Social network; Service provider: X Internet Unlimited Company, One Cumberland Place, Fenian Street, Dublin 2 D02 AX07, Ireland; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://x.com. Privacy policy: https://x.com/de/privacy.

Changes and updates

We ask that you regularly review the content of our privacy policy. We will amend the privacy policy as soon as changes to our data processing practices make this necessary. We will inform you as soon as the changes require action on your part (e.g., consent) or other individual notification.

If we provide addresses and contact information for companies and organizations in this privacy policy, please note that the addresses may change over time and check the information before contacting them.

Definition of terms

This section provides an overview of the terms used in this privacy policy. Where the terms are defined by law, their legal definitions apply. The following explanations are primarily intended to aid understanding.

  • Inventory data: Inventory data includes essential information necessary for the identification and management of contractual partners, user accounts, profiles, and similar assignments. This data may include personal and demographic information such as names, contact information (addresses, telephone numbers, email addresses), dates of birth, and specific identifiers (user IDs). Inventory data forms the basis for any formal interaction between individuals and services, institutions, or systems by enabling unique assignment and communication.
  • Content data: Content data includes information generated in the course of creating, editing, and publishing content of all kinds. This category of data can include text, images, videos, audio files, and other multimedia content published on various platforms and media. Content data is not limited to the actual content itself, but also includes metadata that provides information about the content, such as tags, descriptions, author information, and publication dates.
  • Contact data: Contact data is essential information that enables communication with individuals or organizations. It includes telephone numbers, postal addresses, and email addresses, as well as communication tools such as social media handles and instant messaging identifiers.
  • Meta, communication, and procedural data: Meta, communication, and procedural data are categories that contain information about how data is processed, transmitted, and managed. Meta data, also known as data about data, includes information that describes the context, origin, and structure of other data. It can include details such as file size, creation date, document author, and change history. Communication data captures the exchange of information between users across various channels, such as email correspondence, call logs, social media messages, and chat histories, including the individuals involved, timestamps, and transmission routes. Procedural data describes the processes and procedures within systems or organizations, including workflow documentation, transaction and activity logs, and audit logs used to track and verify operations.
  • Usage data: Usage data refers to information that tracks how users interact with digital products, services, or platforms. This data includes a wide range of information that shows how users use applications, which features they prefer, how long they stay on certain pages, and which paths they navigate through an application. Usage data may also include frequency of use, timestamps of activities, IP addresses, device information, and location data. It is particularly valuable for analyzing user behavior, optimizing user experiences, personalizing content, and improving products or services. In addition, usage data plays a crucial role in identifying trends, preferences, and potential problem areas within digital offerings.
  • Personal data: “Personal data” means any information relating to an identified or identifiable natural person (hereinafter referred to as “data subject”); A natural person is considered identifiable if they can be identified, directly or indirectly, in particular by association with an identifier such as a name, an identification number, location data, an online identifier (e.g., cookie), or one or more special characteristics that express the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
  • Log data: Log data is information about events or activities that have been logged in a system or network. This data typically includes information such as timestamps, IP addresses, user actions, error messages, and other details about the use or operation of a system. Log data is often used to analyze system problems, monitor security, or generate performance reports.
  • Controller: “Controller” means the natural or legal person, public authority, agency, or other body that, alone or jointly with others, determines the purposes and means of the processing of personal data.
  • Processing: “Processing” means any operation or set of operations which is performed on personal data, whether or not by automated means. The term is broad and covers virtually any handling of data, whether it be collection, evaluation, storage, transmission, or deletion.

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