Data Privacy

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    Data Privacy

    Protecting your privacy is of utmost importance to us at Spell GmbH. In handling your personal data, we strive to achieve the greatest possible safety and security and your data will be processed carefully and in accordance with the relevant legal regulations. Your will neither be published by us nor passed on to third parties without authorization. Below we will explain which data will be collected during your stay on our website, and how they will be used.

    1. Name and contact details of the responsible persons

    This privacy policy informs about the processing of personal data on the company website of:

    Keyvan Seiraffi 
    Thomas Sutor

    Spell GmbH 
    Kleinoberfeld 1 
    76135 Karlsruhe 

    Telefon +49 7214647080
    Telefax +49 72146470888 
    [email protected]

    Contact details of the data protection officer:

    The data protection officer of Spell GmbH can be reached at the above address and under [email protected].

    Alexander Lacueva Deutsch 
    Data protection officer 
    Spell GmbH 
    Kleinoberfeld 1 
    76135 Karlsruhe  

    2. Scope and purpose of the processing of personal data

    2.1 Accessing our website

    When accessing our website,, your browser automatically sends data which our server records (server log). Until the automatic deletion, the following data is stored without further input by the visitor:

    • The IP address of your terminal
    • The date and time of your access visited on our website
    • The address of the internet site from which you accessed our website
    • Your browser and operating system ID and the name of the access provider used

    The processing of personal data is in accordance with. Article 6 (1) (1) (f) of the GDPR. Spell GmbH has a legitimate interest in the processing of data for the purpose of,

    • quick connection to the insurance service website,
    • to enable a user-friendly application of the website,
    • to identify and ensure the safety and stability of the systems and to facilitate and improve the administration of the website.

    The processing is not for the purpose of gaining knowledge about the person visiting the website.

    3. Disclosure of data

    Personal data will be transmitted to third parties, if,

    • was expressly consented to by the data subject pursuant to Article 6 (1) (1) (a) GDPR,
    • disclosure pursuant to Article 6 (1) (1) (f) GDPR is required to assert, exercise or defend legal claims and there are no grounds for acceptance, that the person concerned has an overriding legitimate interest in non-disclosure of their data,
    • For the transfer of data according to Art. 6 (1) sentence 1 letter c) GDPR a legal obligation exists and / or this according to Art. 6 (1) sentence 1 letter b) GDPR for the fulfilment of a contractual relationship with the data subject is required.

    4. Cookies

    Cookies are used on our website. These are data packets that are exchanged between our website’s server and the visitor’s browser. When visiting the website, these are stored by the devices used in each case (PC, notebook, tablet, smartphone, etc.). Cookies can not cause any damage to the used devices. Notably, they contain no viruses or other harmful software. Information is stored in accordance to the devices used. Under no circumstances, can Spell be immediately aware of the identity of the visitor to the website.

    Cookies are largely accepted according to the basic settings of the browser. The browser settings can be set up so that cookies are either not accepted on the devices used or that a special notice is given before a new cookie is created. It should be noted, however, that the deactivation of cookies may result in not all the features of the website being used in the best possible way.

    We employ cookies in order to facilitate your use of our website and tailor it to your needs. For example, session cookies can be used to track whether the visitor has already visited individual pages on the website. After leaving the website, these session cookies are automatically deleted.

    To improve usability, temporary cookies are used. They are stored on the visitor’s device for a temporary period of time. Upon re-visiting the website, it is automatically recognized that the visitor has visited the site previously and what inputs and settings have been made in order to avoid repetition.

    Cookies are also used to analyse website views for statistical purposes and for the purpose of improving the offer. These cookies make it possible to automatically recognize pages already accessed by the visitor. These sessions cookies are automatically deleted after leaving the website.

    The data processed by cookies are for the o. G. Justification of the legitimate interests of Spell under Article 6 (1) (1) (f) GDPR.

    5. Analysis services for websites, tracking 

    The legal basis for using the analysis tools is Article 6 (1) (1) (f) GDPR. The website analysis is in the legitimate interest of our company and serves the purpose of the statistical collection of the page usage for the continuous improvement of our company website and offer our services. 


    This website uses Google Analytics, a web analytics service provided by Google Inc. Google Analytics is a web analytics tool that enables website owners to analyse how visitors interact with their websites.

    Google Analytics: This website uses Google Analytics, a web analytics service provided by Google Inc. (“Google”). Google Analytics uses so-called “cookies”, text files that are stored on your computer and that allow you an analysis of the use of the website. The information generated by the cookie about your use of this website is usually transmitted to a Google server in the USA and stored there. However, if IP anonymisation is activated on this website, your IP address will be shortened by Google beforehand within member states of the European Union or other contracting states to the European Economic Area Agreement. Only in exceptional cases will the full IP address be sent to a Google server in the US and shortened there. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activity and to provide other services related to website activity and internet use to the website operator. The IP address provided by Google Analytics as part of Google Analytics will not be merged with other Google data. You can prevent the storage of cookies by a corresponding setting on your browser software. However, we point out that in this case you may not be able to fully use all the functions of this website. In addition, you may prevent the collection by Google of the data generated by the cookie and related to your use of the website (including your IP address) as well as the processing of this data by Google by downloading and installing the browser plug-in available under the following link. In view of the discussion about the use of analysis tools with full IP addresses, we would like to point out that this website uses Google Analytics with the extension “_anonymizeIp ()” and therefore IP addresses are only processed in abbreviated form in order to exclude a direct personal reference.

    6. Your rights as the concerned person

    In so far as your personal data is processed during your visit to our website, you have the following rights as “data subject” within the meaning of the GDPR:

    6.1 Information desk

    You can ask us for information about whether personal data is processed by us. No right of access exists, if the granting of the coveted information risks a breach of confidentiality acc. § 83 StBerG or if the information has to be kept secret because of various reasons or particularly in the case of legitimate prevailing interests. Deviating from this, there can be an obligation to provide the information if your interests outweigh the interests of secrecy, especially taking into account any threatening damage. The right of access is also excluded if the data is stored only because they may not be deleted due to statutory or statutory retention periods or serve exclusively for data protection or data protection purposes, if the disclosure would require a disproportionate effort and processing other purposes is excluded by appropriate technical and organizational measures. If in your case the right to information is not excluded and your personal data is processed by us, you can ask us for information about the following information:

    • purposes of processing,
    • categories of personal data that you process,
    • recipients or categories of recipients to whom your personal data are disclosed, in particular for beneficiaries in third countries,
    • if possible, the planned duration for which your personal data will be stored or, if this is not possible, the criteria for the determination of the storage duration,
    • the right of rectification or erasure or restriction of the processing of personal data concerning you or a right of opposition to such processing,
    • the existence of a right to appeal to a data protection supervisory authority,
    • if the personal data has not been collected from you as the data subject, the information available on the origin of the data,
    • the existence of automated decision-making, including profiling and meaningful information on the logic involved, as well as the scope and intended impact of automated decision-making, where appropriate,
    • if applicable, in the case of transmission to recipients in third countries, unless there is a decision by the EU Commission on the adequacy of the protection level under Art. 45 (3) GDPR, information on which suitable guarantees pursuant to Art. Art. 46 para. 2 GDPR for the protection of personal data.
    • The personal data is no longer necessary for the purposes for which they were processed.
    • The justification for processing was only with your consent, which you have revoked.
    • You have objected to the processing of your personal data that we have made public.
    • You have objected to the processing of personal data not disclosed to us and there are no legitimate reasons for the processing.
    • Your personal data has been processed unlawfully.
    • The deletion of personal data is required to fulfil a legal obligation to which we are subject.
    • You deny the accuracy of your personal data. The restriction may be required in this case for the duration that allows us to verify the accuracy of the data.
    • The processing is unlawful and you require instead of deletion the restriction of the use of your personal data.
    • Your personal information is no longer needed by us for the purposes of processing, but you need to assert, exercise or defend legal claims.
    • You have objected to gem. Art. 21 para. 1 DSGVO. The limitation of processing may be required as long as it is not certain that our justified reasons outweigh your reasons.

    6.2 Correction and completion

    If you discover that we have inaccurate personal information, you may require us to promptly correct this incorrect information. In the case of incomplete personal data concerning yourself, you may request completion.

    6.3 Deletion

    You have the right to erasure (“right to be forgotten”), unless the processing is necessary to exercise the right of freedom of expression, the right to information or to fulfil a legal obligation or to perform a task in public interest and one of the following is true:

    There is no entitlement to cancellation if, in the case of legitimate non-automated data processing, deletion is not possible or only possible with disproportionately high outlay due to the special nature of the storage and your interest in deletion is low. In this case, the deletion is replaced by the restriction of processing.

    6.4 Restriction of processing

    You may require us to restrict processing if any of the following applies:

    Restriction of processing means that the personal data will be processed only with your consent or to assert, exercise or defend legal claims or to protect the rights of another natural or legal person or for reasons of important public interest. Before we lift the restriction, we have a duty to inform you.

    6.5 Data portability

    You have the right of data transferability if the processing is based on your consent (Article 6 (1) sentence 1 (a) or Article 9 (2) (a) GDPR) or on a contract to which you are a party and the processing is done using automated procedures. The right to data portability in this case includes the following rights, provided that this does not affect the rights and freedoms of others: You may require us to provide the personal information you provide to us in a structured, common and machine-readable format to obtain. You have the right to transmit this data to another person without hindrance on our part. As far as technically feasible, you may require that we transfer your personal data directly to another person in charge.

    6.6 Contradiction

    In so far as the processing is based on Article 6 (1) sentence 1 (e) of the GDPR (exercise of a task in the public interest or in the exercise of official authority) or on Article 6 (1) (1) (f) GDPR (legitimate interest of the controller or a third party), you have the right, at any time, to object to the processing of the personal data concerning you for reasons for your particular situation. This also applies to a profiling based on Art. 6 (1) sentence 1 letter e) or letter f) of the GDPR. After exercising your right to object, we will no longer process your personal information unless we can demonstrate compelling legitimate grounds for processing that outweigh your interests, rights and freedoms, or processing for the purposes of asserting, exercising or defending legal claims.

    You may at any time object to the processing of the personal data related to you for direct marketing purposes. This also applies to a profiling associated with such direct mail. After exercising this right of objection, we will no longer use the personal data concerned for direct marketing purposes.

    You have the option of informing us of the opposition by telephone, e-mail or to our company’s postal address listed at the beginning of this privacy policy.

    6.7 Revocation of consent

    You have the right to revoke your consent with future effect at any time. The revocation of the consent, can be communicated informally by phone, e-mail or to our postal address. The revocation does not affect the lawfulness of the data processing that was carried out on the basis of the consent until receipt of the revocation. Upon receipt of the revocation, the data processing, which was based solely on your consent, is discontinued.

    6.8 Complaint

    If you believe that the processing of your personal information is unlawful, you may lodge a complaint with a data protection supervisory authority that has jurisdiction over your place of residence or employment or the location of the alleged breach.

    7. Status and Update of the Privacy Policy

    This Privacy Policy has the status of 05.06.2018. We reserve the right to update the privacy statement in due course to improve privacy and / or adapt it to changes in regulatory practice or jurisdiction.


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