Privacy Statement

SPRICK CYCLE GmbH (SPRICK CYCLE) takes your legitimate data protection concerns very seriously and observes the provisions of the General Data Protection Regulation (GDPR), the Federal Data Protection Act (BDSG-new), the Telecommunications Telemedia Data Protection Act (TTDSG) and, if applicable, the provisions of other applicable data protection regulations.

SPRICK CYCLE handles the data transmitted by you carefully and with due diligence. As far as data of any kind is collected, processed or used, this is always done within the scope of the applicable legal provisions or after obtaining explicit consent from you.

Protecting the individual’s privacy on the Internet is crucial to the future of Internet-based business models and the move toward a true Internet economy. SPRICK CYCLE has created this privacy statement to demonstrate its firm commitment to the individual’s right to privacy. The following outlines SPRICK CYCLE’s personal information handling practices for this website.

This Privacy Statement covers this website and all other sites that reference this Privacy Statement. Some SPRICK CYCLE entities may have their own, possibly different, privacy statements. We encourage you to read the privacy statements of each of the SPRICK CYCLE websites you visit.

Collection and processing

Every access to our website and the retrieval of files stored on the website are logged. This includes: file names retrieved, date and time of retrieval, amount of data transferred, notification of successful retrieval, web browser and requesting domain. The storage serves internal statistical purposes. Additionally, the IP addresses of the requesting computers are logged. Further personal data is only collected if you provide this information voluntarily, for example as part of an inquiry, order or registration.

Use and distribution

The personal data you provide will be treated confidentially by us and will only be passed on to third parties if this is necessary for order processing, such as passing on order data to suppliers. Under no circumstances will we rent or sell your personal data or data relating to you to third parties for their use.

The data controller according to Art. 4 Para. 7 of the General Data Protection Regulation (GDPR) is:

SPRICK CYCLE GmbH
registered in the Commercial Register at the District Court Gütersloh, HRB 6868
Schulstrasse 10
33330 Gütersloh
E-Mail: info@sprick-cycle.de
Tel. +49 5241 – 1794 – 0

You can contact our data protection officer at:

SPRICK CYCLE GmbH
Thomas Fletschinger
Schulstrasse 10

33330 Gütersloh
E-Mail: dsb@sprick-cycle.de

Global Privacy Fundamentals

Our privacy practices reflect current global principles and standards on handling personal information. These principles include notice of data use, choice of data use, data access, data integrity, security, onward transfer, and enforcement/oversight. SPRICK CYCLE abides by the EU General Data Protection Regulation (GDPR)

Consent
By using this website, you consent to the electronic collection and use of your information as described here. If SPRICK CYCLE decides to make changes to this Privacy Statement, we will post the changes on this site so that you will always know what information we collect and how we use it.

From time to time, as may be required by applicable law, we may also seek your explicit consent to process certain data and information collected on this website or volunteered by you.

Collection and Processing of Your Personal Data
To serve you better and understand your needs and interests, SPRICK CYCLE collects and uses personal information with adequate notice and consent, along with required filings with data protection authorities, when applicable.

When you visit our website, we may record your IP address and use cookies and other Internet technologies (referred to below as “Automated Tools” and “Embedded Web Links”) to gather general information about our visitors and their interests. The technologies used and the information collected are described in more detail below.

We may further collect and process any information and data that you volunteer to us, e.g. when you register for events, subscribe to newsletters, participate in online surveys, discussion groups or forums, or when you make purchases.

Use and Purpose of Collected Personal Data
The information SPRICK CYCLE collects to understand your needs and interests helps SPRICK CYCLE deliver a consistent and personalized experience. SPRICK CYCLE will use such information only as described in this Privacy Statement and/or in the way specified at the time of collection. We will not subsequently change the way your personal data is used without your consent, unless this is otherwise permitted by law.

We process your data for the following purposes:

In particular, we may process your personal data for the following purposes:

– to maintain our relationship with you, e.g. via our databases in which we merge data about you from our various sources to get an overview of how we work together; also to improve and personalize our understanding of your preferences and our communications with you;

– to process orders and deliver ordered services and products.

– to perform tasks in preparation or fulfilment of contracts

– to keep records of business transactions.

– to provide you with appropriate and up-to-date information and our products and services

– to improve the quality of our products and services by customizing our offering to your specific needs

– to respond to your enquiries and provide you with efficient support

– to invite you to events sponsored or used by us (e.g. lectures, conferences)

– to provide you with access to our specified IT systems to enable you to use certain SPRICK CYCLE services;

– to manage our IT resources, including infrastructure management and business continuity.

– to protect the commercial interests of the business and to ensure compliance and reporting (e.g. compliance with our policies and local legal requirements, taxes and deductions, compliance with internally set grant limits, managing alleged cases of misconduct or fraud, conducting audits and litigation defence);

– for archiving and record keeping.

– for processing job enquiries

– for invoicing and accounting and

– other purposes required by law and regulatory authorities

– in certain cases, we are legally obliged to transmit data to a requesting government body (institution or authority). The legal basis for processing is Art. 6 Para. 1 c GDPR or Section 24 Para. 2 No. 1 BDSG.

– In some cases, business partners require personal data from our customers. This usually takes place in the context of order fulfilment (e.g. in the event of complaints). This is expressly provided for by law. In this case, SPRICK CYCLE remains responsible for the protection of your data – in addition to the processor, if applicable. The respective business partner works in accordance with our instructions, which SPRICK CYCLE ensures through strict contractual regulations.

– To fulfil the legal obligations to record, document and report to the responsible authorities.

IP Addresses
We use IP addresses to help diagnose problems, to administer our website, and to gather demographic information. We may also use IP addresses or other information you have shared on this website to determine which pages on our sites are being visited and topics that may be of interest so we can provide you with information about relevant products and services. Generally, SPRICK CYCLE will aggregate such data only in an anonymous way and will not tie it to a particular individual unless he or she has given consent. When you visit our site, we recognize only your domain name.

SPRICK CYCLE will only gather information related to your visit to the SPRICK CYCLE website. We do not track or collect personal information from your visits to companies or entities outside the SPRICK CYCLE group of companies.

Cookies
a) We use cookies on our website(s). These are small files that your browser automatically creates and stores on your device (laptop, tablet, smartphone, etc.) when you visit our websites. Cookies cannot do damage to your computer and do not contain viruses, Trojans or any other malware. The information stored in the cookie pertains to the specific device used. This, however, does not give us direct knowledge of your identity. The use of cookies serves to make using our online services more pleasant for you. For example, we use what are known as session cookies to determine that you have already visited individual pages on our website. These are automatically deleted after leaving our website.

b) In addition, to further improve usability, we also use temporary cookies that are stored on your device for a specified period of time. If you visit our website again to use our services, we will automatically determine that you have already visited our website and what inputs and settings you have made in order to avoid having to re-enter them.
c) Furthermore, we use cookies to statistically record the use of our website and to analyze it for the purpose of optimizing our website offerings. These cookies enable us to automatically determine that you have visited our website before. These cookies are automatically deleted after a defined period of time.
d) The data processed by cookies are necessary for the purposes mentioned in order to safeguard our legitimate interests and the interests of third parties under Art. 6 Para.1 Sent. 1 (f) GDPR.
e) Most browsers accept cookies automatically. You can, however, configure your browser in such a way that no cookies are stored on your computer or that a notice is displayed before a new cookie is created. Disabling cookies completely, however, may mean that you will not be able to all the features on our website.

Email Addresses
If you choose to give us your email address or submit it through our contact form, we will communicate with you via email. We do not share your email address with others outside the SPRICK CYCLE group of companies. You can choose not to receive any more emails from SPRICK CYCLE at any time.

Depending on how your email application is set up, information about you may be transmitted automatically when you send an email to SPRICK CYCLE.

Orders or Event Registration
Our site includes order forms that you fill out to request information, products, and services.

External Service Providers
We work with service providers that process certain data on our behalf. This is done exclusively in accordance with the applicable data protection laws. In particular, we have entered into commissioned data processing agreements with our service providers which satisfy the requirements of Art. 28 GDPR.

Information About the Newsletter and Consent
With the following information, we inform you about the content of our newsletter as well as the registration, sending and statistical analysis procedures as well as your right of objection. By subscribing to our newsletter, you agree to the receipt and the procedures described.

Content of the Newsletter
We send newsletters, emails and other electronic notifications with promotional information (hereinafter referred to as “newsletter”) only with the consent of the recipient or a legal permission. The content of the newsletter described as part of the newsletter registration are authoritative for the consent of the users.

Double Opt-in and Logging
Subscribing to our newsletter involves what is known as a double opt-in process. This means that after subscribing, you will receive an email requesting that you confirm your subscription. This confirmation is necessary to verify that you are subscribing with your own email address. Subscriptions to the newsletter are logged in order to be able to verify that the subscription process was consistent with legal requirements. This includes storing the time of subscription and confirmation as well as the IP address.

Credentials
To sign up for the newsletter, it is sufficient to enter your email address. We also use additional data such as last and first name, country, and customer group. The sole purpose of the information provided is personalization and segmentation of the newsletter.

Statistical Survey and Analysis
The newsletters contain a “web beacon”, that is, a pixel-sized file that is retrieved when the newsletter is opened. With this retrieval, technical information such as information about the browser and your system as well as your IP address and the time of retrieval is initially collected. This information serves to improve the technical performance of services based on the technical data or target audiences and their reading habits, based on their locations (which can be determined using the IP address) or access times.

These statistical surveys also include determining whether newsletters are opened, when they are opened and which links are clicked. Even though this information can be attributed to individual newsletter recipients for technical reasons we do not endeavor to monitor individual users. Rather, these analytics serve to determine the reading habits of our users and to adapt our content accordingly or to send different content that accommodates the interests of our users.

Data Transfer, Transfer to a Third Country

Your personal data will not be transferred to third parties for any purposes other than those set out below. We will only transfer your personal data to third parties if:

a) You have given your express consent in accordance with Art. 6 Para. 1 Sent. 1 (a) GDPR, Art. 26 Para. 2 German Federal Data Protection Act (BDSG);
b) The transfer is necessary in accordance with Art. 6 Para. 1 Sent. 1 (f) GDPR for the purpose of asserting, exercising or defending legal claims, and there is no reason to assume that you have an overriding interest worthy of protection in not disclosing your data;
c) In the event that there is a legal obligation to transfer the data pursuant to Art. 6 Para. 1 Sent. 1 (c) GDPR and
d) This is legally permissible and necessary under Art. 6 Para. 1 Sent. 1 (b) GDPR, Art. 26 Para. 1 German Federal Data Protection Act (BDSG) for the execution of a contractual relationship with you or for pre-contractual measures at your request.

Transfer to a third country or an international organization is not intended and there is no automated decision making, including profiling, unless otherwise provided in this Privacy Statement.

SPRICK CYCLE may also share such information with business partners, service vendors, authorized third-party agents or contractors in order to provide a requested service or transaction, including processing orders, providing customer support, or providing you with information on products and services that may be of interest to you.

We do not sell or rent your personal data to third parties for marketing purposes unless you have granted us permission to do so.

SPRICK CYCLE may respond to subpoenas, court orders, or legal process by disclosing your personal data and other related information, if necessary. We also may choose to establish or exercise our legal rights or defend against legal claims.

Circumstances may arise where, whether for strategic or other business reasons, SPRICK CYCLE decides to sell, buy, merge, or otherwise reorganize businesses. Such a transaction may involve, in accordance with applicable law, the disclosure of personal information to prospective or actual purchasers. It is SPRICK CYCLE’s practice to seek appropriate protection for information in these types of transactions.

We may collect and possibly share personal data and any other additional information available to us in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, or violations of SPRICK CYCLE’s terms of use, or as otherwise required by law.

Analysis Tools

The tracking measures listed below and used by us are carried out based on Art. 6 Para. 1 Sent. 1 (f) GDPR. With the tracking measures used, we want to ensure a needs-based design and the continuous optimization of our website. Furthermore, we use tracking measures to statistically record the use of our website and to analyze it for the purpose of optimizing our website offerings. These interests are considered legitimate within the meaning of the aforementioned provision. For the respective data processing purposes and data categories, please refer to the corresponding tracking tools described in detail below.

Privacy Statement for the use of Google Analytics 4 (with cookies, with UserID)

This website uses Google Analytics 4, a service provided by Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland (‘Google’), which can be used to analyse the use of websites.

When using Google Analytics 4, so-called ‘cookies’ are used as standard. Cookies are text files that are stored on your end device and enable your use of a website to be analysed. The information collected by cookies about your use of the website (including the IP address transmitted by your device, shortened by the last digits, see below) is usually transmitted to a Google server, where it is stored and processed. This may also result in information being transmitted to the servers of Google LLC based in the USA and further processing of the information there.

When using Google Analytics 4, the IP address transmitted by your end device when you use the website is always collected and processed in anonymised form by default and automatically, so that the information collected cannot be directly linked to a person. This automatic anonymisation takes place by Google truncating the IP address transmitted by your device within member states of the European Union (EU) or other signatory states to the Agreement on the European Economic Area (EEA).

Google uses this and other information on our behalf to evaluate your use of the website, to compile reports on your website activities and usage behaviour and to provide us with other services relating to your use of the website and the Internet. The abbreviated IP address transmitted by your device as part of Google Analytics 4 will not be merged with other Google data. The data collected as part of the use of Google Analytics 4 is stored for 2 months and then deleted.

Google Analytics 4 also enables the creation of statistics with statements about age, interest-based advertising and the use of third-party information via a special function, the so-called ‘demographic characteristics’. This makes it possible to determine and differentiate between user groups of the website for the purpose of target group-optimised marketing measures. However, data collected via the ‘demographic characteristics’ cannot be assigned to a specific person and therefore not to you personally. This data collected via the ‘demographic characteristics’ function is stored for two months and then deleted.

All processing described above, in particular the setting of Google Analytics cookies for the storage and reading of information on the end device you use to access the website, will only take place if you have given us your express consent to do so in accordance with Art. 6 para. 1 lit. a GDPR. Without your consent, Google Analytics 4 will not be used during your use of the website. You can revoke your consent at any time with effect for the future. To exercise your revocation, please deactivate this service using the ‘cookie consent tool’ provided on the website. In connection with this website, the ‘UserIDs’ function is also used as an extension of Google Analytics 4. By assigning individual UserIDs, we can have Google create cross-device reports (so-called ‘cross-device tracking’). This means that if you have given your consent to the use of Google Analytics 4 in accordance with Art. 6 para. 1 lit. a GDPR, your usage behaviour can also be analysed across devices if you have set up a personal account by registering on this website and have logged in with Google Analytics 4.

We have concluded a so-called order processing contract with Google for our use of Google Analytics 4, which obliges Google to protect the data of our website users and not to pass it on to third parties.

For data transfers to the USA, the provider has signed up to the EU-US Data Privacy Framework, which ensures compliance with the European level of data protection on the basis of an adequacy decision by the European Commission.

Google’s privacy policy can be viewed here: https://www.google.de/policies/privacy/

Details on the processing triggered by Google Analytics 4 and how Google handles data from websites can be found here:

https://policies.google.com/technologies/partner-sites

We use the ‘Microsoft Teams’ service of Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399 USA (hereinafter ‘Microsoft Teams’) to conduct online meetings, video conferences and/or webinars. Different data is processed when Microsoft Teams is used.

The scope of the data processed depends on the data you provide before or during participation in an online meeting, video conference or webinar. When using Microsoft Teams, data of the communication participants is processed and stored on Microsoft Teams servers. This data may include, in particular, your login data (name, email address, telephone (optional) and password) and meeting data (topic, participant IP address, device information, description (optional)).

In addition, visual and audio contributions from participants as well as voice input in chats may be processed. When processing personal data that is necessary for the fulfilment of a contract with you (this also applies to processing operations that are necessary for the implementation of pre-contractual measures), Art. 6 para. 1 lit. b GDPR serves as the legal basis. If you have given us your consent to process your data, the processing is carried out on the basis of Art. 6 para. 1 lit. a GDPR. Consent given can be revoked at any time with effect for the future. Otherwise, the legal basis for data processing when conducting online meetings, video conferences or webinars is our legitimate interest in the effective conduct of the online meeting, webinar or video conference in accordance with Art. 6 para. 1 lit. f GDPR.

Links to Other Websites
Our website may contain links to third-party websites. SPRICK CYCLE is not responsible for the privacy practices or the content of other websites outside of SPRICK CYCLE.

Data Storage
SPRICK CYCLE will not retain your personal data longer than is necessary to fulfill the purposes for which it was collected or as required by applicable laws or regulations.

Information on Data Processing for the Purpose of Application Pursuant to Art. 13 GDPR

Your submitted applicant data will be electronically processed and stored until the application process is concluded.

Collection and Storage of Personal Data as Well as Type and Purpose and Their Use
If you contact us as part of your application, we will collect the following information:

Title, first name, last name, valid email address
Address
Phone number (landline and/or cell phone)
Information we need for the application process

This data is collected for the purpose of correspondence with you. The data is processed as a consequence of your application and, pursuant to Art. 6 Para. 1 Sent. 1 (b) GDPR, is required for the purposes stated for the proper processing of your application. Your personal data will not be transferred to third parties.

Access to the Data
The data provided by you will be treated confidentially. In dealing with a specific job application, only persons who are involved in filling this position have access to the data you have provided. Specifically, these are the employees of the HR department of SPRICK CYCLE, its management, and the respective division managers.

Deletion of the Data
We will only store and use your information for as long as is necessary to decide whether to enter into an employment relationship with you. If you receive a rejection of your application, the application process is complete.

Your personal application data will be automatically deleted six months after completion of the application process. This does not apply if legal provisions prevent the deletion, as further storage is necessary for the purpose of presenting evidence, or if you have consented to further storage in accordance with Art. 6 Para. 1 Sent. 1 (a) GDPR.

Data Subject Rights

You have the right

a) In accordance with Art. 15 GDPR, to request information about your personal data processed by us. In particular, you may request information about the purposes of processing, the categories of personal data concerned, the categories of recipients to whom your personal data have been or will be disclosed, the planned storage period, the existence of the right to rectification, deletion, restriction or objection of processing of personal data, the right to lodge a complaint with a supervisory authority, the origin of your data where the personal data was not collected by us, and the existence of automated decision-making including profiling and, if applicable, meaningful information about the logic involved;
b) In accordance with Art. 16 GDPR, to demand without delay the correction of incorrect data or the completion of your personal data stored by us;
c) To request the deletion of your personal data stored with us in accordance with Art. 17 GDPR, unless the processing is necessary to exercise the right to freedom of expression and information, to fulfill a legal obligation, for reasons of public interest or to assert, exercise or defend legal claims;
d) In accordance with Art. 18 GDPR to restrict the processing of your personal data if you dispute the accuracy of the data, if the processing is unlawful but you reject its deletion and we no longer need the data, but you need it to assert, exercise or defend legal claims, or if you have filed an objection to the processing in accordance with Art. 21 GDPR;
e) In accordance with Art. 20 GDPR, to receive your personal data that you have provided to us in a structured, common and machine-readable format or to request its transfer to another person responsible;
f) In accordance with Art. 7 Para. 3 GDPR, to revoke your consent to us at any time. As a result, we will no longer be allowed to continue processing the data based on this consent in the future and
g) In accordance with Art. 77 GDPR, to complain to a supervisory authority. As a general rule, you can contact the supervisory authority of your usual place of residence or workplace or of the registered office of our company.

The competent supervisory authority for data protection for SPRICK CYCLE is:

Die Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen

[The State Commissioner for Data Protection and Freedom of NRW)
Postfach 20 04 44, 40102 Düsseldorf, Kavalleriestraße 2-4, 40213 Düsseldorf

Tel: 0211 38424 – 0, Fax: 0211 38424 – 10

Mail: poststelle@ldi.nrw.de , Internet: http://www.ldi.nrw.de

For the assertion of the afore mentioned rights as well as for questions regarding data protection, you can contact the data controller pursuant to section 1 above or send a corresponding email to dsb(at)sprick-cycle.de

Right to Object

If your personal data are processed on the basis of legitimate interests pursuant to Art. 6 Para. 1 Sent. 1 (f) GDPR, you have the right to object to the processing of your personal data pursuant to Art. 21 GDPR, provided that there are reasons for this which arise from your particular situation or the objection is directed against direct advertising. In the latter case, you have a general right of objection, which we will implement without specifying a particular situation. If you would like to exercise your right of withdrawal or objection, simply send an email to dsb(at)sprick-cycle.de

Data Security
a) While you visit our website, we use the common SSL procedure (Secure Socket Layer) with the highest possible encryption level supported by your browser. As a general rule, this is a 256-bit encryption. If your browser does not support 256-bit encryption, we will resort to128-bit v3 technology instead. Whether an individual page of our website is transmitted in encrypted form is indicated by the display of the closed key/lock symbol in the lower status bar of your browser. The data that you enter in the form for registration in the job exchange will also be transmitted to us only in encrypted form.

b) We also use appropriate technical and organizational security measures to protect your data against accidental or intentional tampering, partial or complete loss, destruction or unauthorized access by third parties. Our security measures are continuously improved in line with technological developments.

Changes to This Privacy Statement

In the event of new developments such as changes to the applicable data privacy laws, we will, if necessary, update this privacy statement accordingly.

Last updated: May 1, 2024