Privacy Policy

Last update: August 2022

An overview of data protection

General information
The following information will provide you with an easy to navigate overview of what will happen with your personal data when you visit this website. The term “personal data” comprises all data that can be used to personally identify you. For detailed information about the subject matter of data protection, please consult our Data Protection Declaration, which we have included beneath this copy. 

Data recording on this website

The data on this website is processed by the operator of the website, whose contact information is available under section “Information about the responsible party (referred to as the “controller”)” in this Privacy Policy.

We collect your data as a result of your sharing of your data with us. This may, for instance, be information you enter into our contact form or register on our website. Other data shall be recorded by our IT systems automatically or after you consent to its recording during your website visit. This data comprises primarily technical information (e.g., web browser, operating system, or time the site was accessed). This information is recorded automatically when you access this website. A portion of the information is generated to guarantee the error free provision of the website. Other data may be used to analyze your user patterns.

You have the right to receive information about the source, recipients, and purposes of your archived personal data at any time without having to pay a fee for such disclosures. You also have the right to demand that your data are rectified or eradicated. If you have consented to data processing, you have the option to revoke this consent at any time, which shall affect all future data processing. Moreover, you have the right to demand that the processing of your data be restricted under certain circumstances. Furthermore, you have the right to log a complaint with the competent supervising agency. Please do not hesitate to contact us at any time if you have questions about this or any other data protection related issues.

Analysis tools and tools provided by third parties
There is a possibility that your browsing patterns will be statistically analyzed when your visit this website. Such analyses are performed primarily with what we refer to as analysis programs. For detailed information about these analysis programs please consult our Data Protection Declaration below.

External Hosting

We are hosting our website with AWS. The provider is Amazon Web Services EMEA SARL, 38 Avenue John F. Kennedy, 1855 Luxembourg (hereinafter referred to as “AWS”). When you visit our website, your personal data will be processed on AWS servers. This may also result in the transfer of personal data to the parent company of AWS in the United States. The transfer of data to the US is based on the EU’s standard contractual clauses. For details please consult: https://aws.amazon.com/de/blogs/security/aws-gdpr-data-processing-addendum/.
For more information, please see the AWS Data Privacy Policy: https://aws.amazon.com/de/privacy/?nc1=f_pr. 

AWS is used on the basis of our legitimate interest in a depiction of our website that is as reliable as possible. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of this consent. The consent can be revoked at any time. We have concluded a data processing agreement (DPA) with the above-mentioned provider. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the applicable data protection laws.

General information on data protection

The operators of this website and its pages take the protection of your personal data very seriously. Hence, we handle your personal data as confidential information and in compliance with the statutory data protection regulations and this Data Protection Declaration. Whenever you use this website, a variety of personal information will be collected. Personal data comprises data that can be used to personally identify you. This Data Protection Declaration explains which data we collect as well as the purposes we use this data for. It also explains how, and for which purpose the information is collected. We herewith advise you that the transmission of data via the Internet (i.e., through e-mail communications) may be prone to security gaps. It is not possible to completely protect data against third-party access.

Information about the responsible party (referred to as the “controller”)

The data processing controller on this website is:

Spectos U.K. Ltd
Chantry House
High Street
Coleshill
Birmingham B46 3BP
United Kingdom

Phone: 0800 090 3148
E-mail: info@spectos.com

The controller is the natural person or legal entity that single-handedly or jointly with others makes decisions as to the purposes of and resources for the processing of personal data (e.g., names, e-mail addresses, etc.).

Storage duration

Unless a more specific storage period has been specified in this privacy policy, your personal data will remain with us until the purpose for which it was collected no longer applies. If you assert a justified request for deletion or revoke your consent to data processing, your data will be deleted, unless we have other legally permissible reasons for storing your personal data (e.g., commercial law retention periods); in the latter case, the deletion will take place after these reasons cease to apply. 

General information on the legal basis for the data processing on this website

If you have consented to data processing, we process your personal data on the basis of this consent. The consent can be revoked at any time. We can also process your data if required for the fulfillment of a contract or for the implementation of pre-contractual measures or if your data is required for the fulfillment of a legal obligation, Furthermore, the data processing may be carried out on the basis of our legitimate interest.

Information on data transfer to the USA and other countries

Among other things, we use tools of companies domiciled in the United States or other from a data protection perspective non-secure countries (compared to GDPR respectively UK standards). If these tools are active, your personal data may potentially be transferred to these countries and may be processed there. We must point out that in these countries, a data protection level that is comparable to GDPR cannot be guaranteed. For instance, U.S. enterprises are under a mandate to release personal data to the security agencies and you as the data subject do not have any litigation options to defend yourself in court. Hence, it cannot be ruled out that U.S. agencies (e.g., the Secret Service) may process, analyze, and permanently archive your personal data for surveillance purposes. We have no control over these processing activities.

Revocation of your consent to the processing of data

Some wide range of data processing transactions are possible only subject to your express consent. You can also revoke at any time any consent you have already given us. This shall be without prejudice to the lawfulness of any data collection that occurred prior to your revocation.

Right to object to the collection of data in special cases; right to object to direct advertising

You may at any time object to the processing of your personal data based on grounds arising from your unique situation. We do not carry out profiling, but your right to object would also apply to profiling. To determine the legal basis, on which any processing of data is based, please consult this data protection declaration. If you log an objection, we will no longer process your affected personal data, unless we are in a position to present compelling protection worthy grounds for the processing of your data, that outweigh your interests, rights and freedoms or if the purpose of the processing is the claiming, exercising or defence of legal entitlements. If your personal data is being processed in order to engage in direct advertising, you have the right to object to the processing of your affected personal data for the purposes of such advertising at any time. This also applies to profiling to the extent that it is affiliated with such direct advertising. If you object, your personal data will subsequently no longer be used for direct advertising purposes.

Right to log a complaint with the competent supervisory agency

Data subjects may appeal to a supervisory authority. The right to log a complaint is in effect regardless of any other administrative or court proceedings available as legal recourses.

Right to data portability

You have the right to demand that we hand over any data we automatically process on the basis of your consent or in order to fulfil a contract be handed over to you or a third party in a commonly used, machine readable format. If you should demand the direct transfer of the data to another controller, this will be done only if it is technically feasible.

Information about, rectification and eradication of data

Within the scope of the applicable statutory provisions, you have the right to at any time demand information about your archived personal data, their source and recipients as well as the purpose of the processing of your data. You may also have a right to have your data rectified or eradicated. If you have questions about this subject matter or any other questions about personal data, please do not hesitate to contact us at any time.

Right to demand processing restrictions

You have the right to demand the imposition of restrictions as far as the processing of your personal data is concerned. To do so, you may contact us at any time. The right to demand restriction of processing applies in the following cases:

• In the event that you should dispute the correctness of your data archived by us, we will usually need some time to verify this claim. During the time that this investigation is ongoing, you have the right to demand that we restrict the processing of your personal data.
• If the processing of your personal data was/is conducted in an unlawful manner, you have the option to demand the restriction of the processing of your data in lieu of demanding the eradication of this data.
• If we do not need your personal data any longer and you need it to exercise, defend or claim legal entitlements, you have the right to demand the restriction of the processing of your personal data instead of its eradication.
• If you have raised an objection, your rights and our rights will have to be weighed against each other. As long as it has not been determined whose interests prevail, you have the right to demand a restriction of the processing of your personal data.
• If you have restricted the processing of your personal data, these data – with the exception of their archiving – may be processed only subject to your consent or to claim, exercise or defend legal entitlements or to protect the rights of other natural persons or legal entities or for important public interest reasons cited by the European Union or a member state of the EU.

SSL and/or TLS encryption

For security reasons and to protect the transmission of confidential content, such as purchase orders or inquiries you submit to us as the website operator, this website uses either an SSL or a TLS encryption program.

You can recognize an encrypted connection by checking whether the address line of the browser switches from “http://” to “https://” and also by the appearance of the lock icon in the browser line. If the SSL or TLS encryption is activated, data you transmit to us cannot be read by third parties.

Recording of data on this website

Cookies

Our websites and pages use what the industry refers to as “cookies.” Cookies are small text files that do not cause any damage to your device. They are either stored temporarily for the duration of a session (session cookies) or they are permanently archived on your device (permanent cookies). Session cookies are automatically deleted once you terminate your visit. Permanent cookies remain archived on your device until you actively delete them, or they are automatically eradicated by your web browser. In some cases, it is possible that third-party cookies are stored on your device once you enter our site (third-party cookies). These cookies enable you or us to take advantage of certain services offered by the third party.

Cookies have a variety of functions. Many cookies are technically essential since certain website functions would not work in the absence of the cookies (e.g., a shopping cart function or the display of videos). The purpose of other cookies may be the analysis of user patterns or the display of promotional messages. Cookies, which are required for the performance of electronic communication transactions, or for the provision of certain functions you want to use (e.g., for a shopping cart function) or those that are necessary for the optimization (required cookies) of the website (e.g., cookies that provide measurable insights into the web audience), shall be stored on the basis of our legitimate interest, unless a different legal basis is cited. The operator of the website has a legitimate interest in the storage of required cookies to ensure the technically error free and optimized provision of the operator’s services. If your consent to the storage of the cookies and similar recognition technologies has been requested, processing occurs exclusively on the basis of the consent obtained. The consent may be revoked at any time.

You have the option to set up your browser in such a manner that you will be notified any time cookies are placed and to permit the acceptance of cookies only in specific cases. You may also exclude the acceptance of cookies in certain cases or in general or activate the delete function for the automatic eradication of cookies when the browser closes. If cookies are deactivated, the functions of this website may be limited.

In the event that third-party cookies are used or if cookies are used for analytical purposes, we will separately notify you in conjunction with this Data Protection Policy and, if applicable, ask for your consent.

Consent with Borlabs Cookie

Our website uses the Borlabs consent technology to obtain your consent to the storage of certain cookies in your browser or for the use of certain technologies and for their data privacy protection compliant documentation. The provider of this technology is Borlabs GmbH, Ruebenkamp 32, 22305 Hamburg, Germany (hereinafter referred to as Borlabs). Whenever you visit our website, a Borlabs cookie will be stored in your browser, which archives any declarations or revocations of consent you have entered. These data are not shared with the provider of the Borlabs technology. The recorded data shall remain archived until you ask us to eradicate them, delete the Borlabs cookie on your own, or the purpose of storing the data no longer exists. This shall be without prejudice to any retention obligations mandated by law. To review the details of Borlabs’ data processing policies, please visit https://borlabs.io/kb/what-information-does-borlabs-cookie-store/.

We use the Borlabs cookie consent technology to obtain the declarations of consent mandated by law for the use of cookies.

Server log files

The provider of this website and its pages automatically collects and stores information in so-called server log files, which your browser communicates to us automatically. The information comprises:

• Type and version of browser used
• Used operating system
• Referrer URL
• Hostname of the accessing computer
• Time of the server inquiry
• IP address

This data is not merged with other data sources. The operator of the website has a legitimate interest in the technically error-free depiction and optimization of the operator’s website. In order to achieve this, server log files must be recorded.

Contact form

If you submit inquiries to us via our contact form, the information provided in the contact form as well as any contact information provided therein will be stored by us in order to handle your inquiry and in the event that we have further questions. We will not share this information without your consent. The processing of these data is based on the execution of a contract or if it is necessary to carry out pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective processing of the requests addressed to us or on your agreement if this has been requested; the consent can be revoked at any time. The information you have entered into the contact form shall remain with us until you ask us to eradicate the data, revoke your consent to the archiving of data, or if the purpose for which the information is being archived no longer exists (e.g., after we have concluded our response to your inquiry). This shall be without prejudice to any mandatory legal provisions, in particular retention periods.

Request by email or telephone

If you contact us by email or telephone, your request, including all resulting personal data (name, request) will be stored and processed by us for the purpose of processing your request. We do not pass these data on without your consent. These data are processed for the fulfillment of a contract or are required for the performance of pre-contractual measures. In all other cases, the data are processed on the basis of our legitimate interest in the effective handling of inquiries submitted to us or on the basis of your consent if it has been obtained; the consent can be revoked at any time. The data sent by you to us via contact requests remain with us until you request us to delete, revoke your consent to the storage or the purpose for the data storage lapses (e.g., after the completion of your request). Mandatory statutory provisions – in particular statutory retention periods – remain unaffected. 

Registration on this website and processing of your data in our panel database

You have the option of registering as a Mailagent via the website in our panel. The data entered are transmitted to us and stored. The following data is collected during the registration process:

• Name and surname;
• Address;
• Contact details (email);
• Date of birth.

The following data is also stored at the time of registration:

• IP address;
• Date and time of your registration.

Your registration takes place on the basis of our Terms and Conditions and with the purpose of evaluating our customers’ products and services. We collect, process, and use your data for the establishment, content, arrangement, and modification of our relationship as described in our Terms and Conditions. We share personal data with third parties only if this is necessary, in conjunction with the handling of our terms and conditions. Any further transfer of data shall not occur or shall only occur if you have expressly consented to the transfer. Any sharing of your data with third parties in the absence of your express consent shall not occur. The basis for the processing of data is the fulfillment of our Terms and Conditions or for pre-contractual actions.

The required information we request at the time of registration must be entered in full. Otherwise, we shall reject the registration. To notify you of any important changes to the scope of our portfolio or in the event of technical modifications, we shall use the e-mail address provided during the registration process. The data recorded during the registration process shall be stored by us as long as you are registered as a mail agent in our panel database. Subsequently, such data shall be deleted. This shall be without prejudice to mandatory statutory retention obligations.

Analysis tools

Google Tag Manager

We use Google Tag Manager. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The Google Tag Manager is a tool that allows us to integrate tracking or statistical tools and other technologies on our website. The Google Tag Manager itself does not create any user profiles, does not store cookies, and does not carry out any independent analyses. It only manages and runs the tools integrated via it. However, the Google Tag Manager does collect your IP address, which may also be transferred to Google’s parent company in the United States. The Google Tag Manager is used on the basis of our legitimate interest in the quick and uncomplicated integration and administration of various tools on his website. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of this consent. This consent can be
revoked at any time.

Google Analytics

This website uses functions of the web analysis service Google Analytics. The provider of this service is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland. Google Analytics enables the website operator to analyze the behavior patterns of website visitors. To that end, the website operator receives a variety of user data, such as pages accessed, time spent on the page, the utilized operating system, and the user’s origin. This data is summarized in a user ID and assigned to the respective end device of the website visitor. Furthermore, Google Analytics allows us to record your mouse and scroll movements and clicks, among other things. Google Analytics uses various modeling approaches to augment the collected data sets and uses machine learning technologies in data analysis. Google Analytics uses technologies that make the recognition of the user for the purpose of analyzing user behavior patterns (e.g., cookies or device fingerprinting). The website use information recorded by Google is, as a rule transferred to a Google server in the United States, where it is stored. The use of these services occurs on the basis of your consent. You may revoke your consent at any time. Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here:
https://privacy.google.com/businesses/controllerterms/mccs/.

You can prevent the recording and processing of your data by Google by downloading and installing the browser plugin available under the following link:
https://tools.google.com/dlpage/gaoptout?hl=en. 

For more information about the handling of user data by Google Analytics, please consult Google’s Data Privacy Declaration at: 
https://support.google.com/analytics/answer/6004245?hl=en. 

We have executed a contract data processing agreement with Google.

Plug-Ins and Tools

Animoto

With the player from Animoto, we integrate our own videos into our pages on the basis of a legitimate interest in the presentation of our services. When you call up a page of our website that contains such a plugin, your browser establishes a direct connection with the servers of Animoto. The content of the plugin (in particular your IP address) is transmitted by Animoto directly to your browser and integrated by it into the website. You can find more information on this in Animoto’s privacy policy: https://animoto.com/legal/privacy_policy.

Google Web Fonts (local embedding)

This website uses so-called Web Fonts provided by Google to ensure the uniform use of fonts on this site. These Google fonts are locally installed so that a connection to Google’s servers will not be established in conjunction with this application. For more information on Google Web Fonts, please follow this link: https://developers.google.com/fonts/faq and consult Google’s Data Privacy Declaration under: https://policies.google.com/privacy?hl=en.

Userlike with extended data privacy mode

We use Userlike (hereinafter called “Userlike”) to process user inquiries via our support channels or live chat systems. The provider is Userlike UG (a limited liability company), Probsteigasse 44 – 46, 50670 Cologne, Germany. Messages you send to us may be stored in the Userlike ticket system or answered by our staff in live chat. When you communicate with us through Userlike, we and Userlike store, among other things, your name and email address, if you have provided them, and your chat history. This data is summarized in a profile. Messages that are addressed to us remain in our possession until you ask us to delete them or the reason for the data storage is no longer effective (e.g., after your inquiry has been processed). This shall be without prejudice to any statutory provisions – especially statutory mandatory retention obligations. Userlike is deployed on the basis of our legitimate interest in marketing activities that are as effective as possible. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of this consent. This consent can be revoked at any time. For more information, please consult the Userlike data protection declaration: https://www.userlike.com/en/data-privacy.

We have concluded a data processing agreement (DPA) with the above-mentioned provider. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the applicable data protection laws.

Handling applicant data

We offer website visitors the opportunity to submit job applications to us (e.g., via e-mail, via postal services on by submitting an online job application form). Below, we will brief you on the scope, purpose and use of the personal data collected from you in conjunction with the application process. We assure you that the collection, processing, and use of your data will occur in compliance with the applicable data privacy rights and all other statutory provisions and that your data will always be treated as strictly confidential.

Scope and purpose of the collection of data

If you submit a job application to us, we will process any affiliated personal data (e.g., contact and communications data, application documents, notes taken during job interviews, etc.), if they are required to make a decision concerning the establishment or an employment relationship. The legal grounds are the negotiation of an Employment Relationship and – provided you have given us your consent – your consent. You may revoke any consent given at any time. Within our company, your personal data will only be shared with individuals who are involved in the processing of your job application. If your job application should result in your recruitment, the data you have submitted will be archived for the purpose of implementing the employment relationship in our data processing system.

Data archiving period 

If we are unable to make you a job offer or you reject a job offer or withdraw your application, we reserve the right to retain the data you have submitted on the basis of our legitimate interests for up to 6 months from the end of the application procedure (rejection or withdrawal of the application). Afterwards, the data will be deleted, and the physical application documents will be destroyed. The storage serves in particular as evidence in the event of a legal dispute. If it is evident that the data will be required after the expiry of the 6-month period (e.g., due to an impending or pending legal dispute), deletion will only take place when the purpose for further storage no longer applies. Longer storage may also take place if you have given your agreement or if statutory data retention requirements preclude the deletion.

Admission to the applicant pool 

If we do not make you a job offer, you may be able to join our applicant pool. In case of admission, all documents and information from the application will be transferred to the applicant pool in order to contact you in case of suitable vacancies. Admission to the applicant pool is based exclusively on your express agreement. The submission agreement is voluntary and has no relation to the ongoing application procedure. The affected person can revoke his agreement at any time. In this case, the data from the applicant pool will be irrevocably deleted, provided there are no legal reasons for storage. The data from the applicant pool will be irrevocably deleted no later than two years after consent has been granted.