Privacy Policy
1. Data protection at a glance
General information
The following information provides a simple overview of what happens to your personal data when you visit this website. Personal data is all data that can be used to identify you personally. Detailed information on data protection can be found in our privacy policy listed below this text.
Data collection on this website
Who is responsible for data collection on this website?
Data processing on this website is carried out by the website operator. You can find their contact details in the "Information on the Responsible Party" section of this privacy policy.
How do we collect your data?
Your data is collected, on the one hand, when you provide it to us. This may, for example, be data you enter in a contact form.
Other data is collected automatically or with your consent by our IT systems when you visit the website. This primarily involves technical data (e.g., internet browser, operating system, or time of page access). This data is collected automatically as soon as you access this website.
What do we use your data for?
Some of the data is collected to ensure the error-free provision of the website. Other data may be used to analyze your user behavior.
What rights do you have regarding your data?
You have the right to obtain information about the origin, recipient, and purpose of your stored personal data free of charge at any time. You also have the right to request the correction or deletion of this data. If you have given your consent to data processing, you can revoke this consent at any time with effect for the future. Furthermore, you have the right to request the restriction of the processing of your personal data under certain circumstances. Furthermore, you have the right to lodge a complaint with the competent supervisory authority.
You can contact us at any time with any questions about this or other issues relating to data protection.
Analysis tools and third-party tools
When you visit this website, your browsing behavior may be statistically analyzed. This is done primarily using so-called analysis programs.
Detailed information about these analysis programs can be found in the following privacy policy.
2. Hosting
We host the content of our website with the following provider:
IONOS
The provider is IONOS SE, Elgendorfer Str. 57, 56410 Montabaur (hereinafter IONOS). When you visit our website, IONOS records various log files, including your IP address. Details can be found in the IONOS privacy policy: https://www.ionos.de/terms-gtc/terms-privacy
The use of IONOS is based on Art. 6 (1) (f) GDPR. We have a legitimate interest in presenting our website as reliably as possible. If consent has been requested, processing will be carried out exclusively on the basis of Art. 6 (1) (a) GDPR and Section 25 (1) TTDSG, insofar as the consent includes the storage of cookies or access to information on the user's device (e.g., device fingerprinting) within the meaning of the TTDSG. Consent can be revoked at any time.
Order processing
We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract required by data protection law, which guarantees that the personal data of our website visitors will only be processed in accordance with our instructions and in compliance with the GDPR.
3. General information and mandatory information
Data protection
The operators of these websites take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with the statutory data protection regulations and this privacy policy.
When you use this website, various personal data is collected. Personal data is data that can be used to identify you personally. This privacy policy explains what data we collect and what we use it for. It also explains how and for what purpose.
We would like to point out that data transmission over the Internet (e.g., when communicating via email) may be subject to security gaps. Complete protection of data from access by third parties is not possible.
Note on the responsible body
The responsible body for data processing on this website is:
mySpirit Germany
a brand of
Trinkwerk GmbH
On the Little Danube 2
89231 Neu-Ulm
Telephone: +49 (0) 731 / 49 39 16- 50
Email: service@myspirit24.com
The responsible body is the natural or legal person who alone or jointly with others decides on the purposes and means of processing personal data (e.g. names, e-mail addresses, etc.).
Storage period
Unless a more specific storage period has been specified in this privacy policy, your personal data will remain with us until the purpose for data processing no longer applies. If you assert a legitimate 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., retention periods under tax or commercial law); in the latter case, deletion will occur once these reasons no longer apply.
General information on the legal basis for data processing on this website
If you have consented to data processing, we will process your personal data on the basis of Art. 6 (1) (a) GDPR or Art. 9 (2) (a) GDPR if special categories of data are processed pursuant to Art. 9 (1) GDPR. In the event of express consent to the transfer of personal data to third countries, data processing will also be carried out on the basis of Art. 49 (1) (a) GDPR. If you have consented to the storage of cookies or to access information on your device (e.g. via device fingerprinting), data processing will also be carried out on the basis of Section 25 (1) TTDSG. Your consent can be revoked at any time. If your data is required to fulfil the contract or to carry out pre-contractual measures, we will process your data on the basis of Art. 6 (1) (b) GDPR. Furthermore, if your data is required to fulfil a legal obligation, we will process it on the basis of Art. 6 (1) (c) GDPR. Data processing may also be based on our legitimate interest pursuant to Art. 6 (1) (f) GDPR. The relevant legal bases in each individual case are explained in the following paragraphs of this privacy policy.
Note on data transfer to third countries that are not secure under data protection law and on transfer to US companies that are not DPF-certified
We use tools from companies based in third countries that are not secure under data protection law, as well as US tools whose providers are not certified under the EU-US Data Privacy Framework (DPF). If these tools are active, your personal data may be transferred to these countries and processed there. We point out that a level of data protection comparable to that in the EU cannot be guaranteed in third countries with unsafe data protection law.
We would like to point out that the USA, as a safe third country, generally offers a level of data protection comparable to that of the EU. Data transfer to the USA is therefore permitted if the recipient is certified under the "EU-US Data Privacy Framework" (DPF) or has appropriate additional safeguards. Information on transfers to third countries, including the data recipients, can be found in this privacy policy.
Recipients of personal data
As part of our business activities, we work with various external parties. In some cases, this also requires the transfer of personal data to these external parties. We only pass on personal data to external parties if this is necessary to fulfill a contract, if we are legally obliged to do so (e.g., passing on data to tax authorities), if we have a legitimate interest in the transfer pursuant to Art. 6 (1) (f) GDPR, or if another legal basis permits the data transfer. When using contract processors, we only pass on our customers' personal data on the basis of a valid contract for order processing. In the case of joint processing, a contract for joint processing is concluded.
Revocation of your consent to data processing
Many data processing operations are only possible with your express consent. You can revoke your consent at any time. The legality of the data processing carried out up to the time of revocation remains unaffected.
Right to object to data collection in special cases and to direct marketing (Article 21 GDPR)
If data processing is based on Art. 6 (1) (e) or (f) GDPR, you have the right to object to the processing of your personal data at any time for reasons arising from your particular situation; this also applies to profiling based on these provisions. The respective legal basis on which processing is based can be found in this data protection declaration. If you object, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which outweigh your interests, rights and freedoms or the processing serves to assert, exercise or defend legal claims (objection pursuant to Art. 21 (1) GDPR).
If your personal data 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 purposes of such advertising; this also applies to profiling insofar as it is related to such direct marketing. If you object, your personal data will subsequently no longer be used for direct marketing purposes (objection pursuant to Art. 21 (2) GDPR).
Right to lodge a complaint with the competent supervisory authority
In the event of violations of the GDPR, data subjects have the right to lodge a complaint with a supervisory authority, in particular in the Member State of their habitual residence, place of work, or place of the alleged violation. This right of complaint is without prejudice to other administrative or judicial remedies.
Right to data portability
You have the right to have data that we process automatically based on your consent or in fulfillment of a contract handed over to you or to a third party in a common, machine-readable format. If you request the direct transfer of the data to another controller, this will only be done if technically feasible.
Information, correction and deletion
Within the scope of applicable law, you have the right at any time to obtain free information about your stored personal data, its origin and recipient, and the purpose of data processing, as well as the right to have this data corrected or deleted. You can contact us at any time with any questions about this or other issues relating to personal data.
Right to restriction of processing
You have the right to request the restriction of the processing of your personal data. You can contact us at any time to do so. The right to restriction of processing exists in the following cases:
If you dispute the accuracy of your personal data stored by us, we generally need time to verify this. You have the right to request that the processing of your personal data be restricted while we verify your personal data.
If the processing of your personal data was/is unlawful, you can request the restriction of data processing instead of deletion.
If we no longer need your personal data, but you require it to exercise, defend or assert legal claims, you have the right to request that the processing of your personal data be restricted instead of deleted.
If you have lodged an objection pursuant to Art. 21 (1) GDPR, your interests must be weighed against ours. As long as it is not yet clear whose interests prevail, you have the right to request that the processing of your personal data be restricted.
If you have restricted the processing of your personal data, this data may – with the exception of its storage – only be processed with your consent or for the establishment, exercise or defense of legal claims or to protect the rights of another natural or legal person or for reasons of important public interest of the European Union or a Member State.
SSL or TLS encryption
This site uses SSL or TLS encryption for security reasons and to protect the transmission of confidential content, such as orders or inquiries that you send to us as the site operator. You can recognize an encrypted connection by the fact that the address line of your browser changes from "http://" to "https://" and by the lock symbol in your browser's address bar.
If SSL or TLS encryption is activated, the data you send to us cannot be read by third parties.
Objection to advertising emails
The use of contact data published in accordance with the imprint obligation to send unsolicited advertising and information materials is hereby prohibited. The operators of the website expressly reserve the right to take legal action in the event of unsolicited advertising information being sent, for example, through spam emails.
4. Data collection on this website
Cookies
Our website uses so-called "cookies." Cookies are small data packets and do not cause any damage to your device. They are stored on your device either temporarily for the duration of a session (session cookies) or permanently (permanent cookies). Session cookies are automatically deleted after your visit. Persistent cookies remain stored on your device until you delete them yourself or until they are automatically deleted by your web browser.
Cookies can originate from us (first-party cookies) or from third-party companies (so-called third-party cookies). Third-party cookies enable the integration of certain third-party services within websites (e.g., cookies for processing payment services).
Cookies serve various functions. Many cookies are technically necessary, as certain website functions would not work without them (e.g., the shopping cart function or displaying videos). Other cookies can be used to evaluate user behavior or for advertising purposes.
Cookies that are required to carry out electronic communication, to provide certain functions you have requested (e.g. for the shopping cart function) or to optimize the website (e.g. cookies to measure web audience) (necessary cookies) are stored on the basis of Art. 6 (1) (f) GDPR, unless another legal basis is specified. The website operator has a legitimate interest in storing necessary cookies for the technically error-free and optimized provision of its services. If consent to the storage of cookies and similar recognition technologies has been requested, processing will take place exclusively on the basis of this consent (Art. 6 (1) (a) GDPR and Section 25 (1) TTDSG); this consent can be revoked at any time.
You can configure your browser to inform you about the use of cookies and to only accept cookies on a case-by-case basis, to exclude cookies for specific cases or in general, and to automatically delete cookies when closing your browser. Disabling cookies may limit the functionality of this website.
You can find out which cookies and services are used on this website in this privacy policy.
Cookiebot Plugin (CCPA ready)
Use of Cookiebot
We use the consent management tool Cookiebot from Cybot A/S, Havnegade 39, 1058 Copenhagen, Denmark (“Cookiebot”) on our website. This tool enables you to withdraw your consent to data processing via the
Website, in particular the setting of cookies, as well as to exercise your right to withdraw consent already granted. Data processing serves the purpose of obtaining and documenting the necessary consent to data processing and thus complying with legal obligations. Cookies may be used for this purpose. Among other things, the following information may be collected:
and transmitted to Cookiebot: anonymized IP address, date and
Time of consent, URL from which the consent was sent,
anonymous, random, encrypted key, consent status. This data will not be passed on to any other third parties.
Data processing is carried out to fulfill a legal obligation on the basis of Art. 6 (1) (c) GDPR. Further information on data protection at Cookiebot can be found at: https://www.cookiebot.com/de/privacy-policy/
This data will not be shared with third parties. Data processing is carried out to fulfill a legal obligation based on Art. 6 (1) (c) GDPR.
Contact form
If you send us inquiries via the contact form, your information from the form, including the contact details you provided there, will be stored by us for the purpose of processing your inquiry and in case of follow-up questions. We will not share this data without your consent.
This data is processed on the basis of Art. 6 (1) (b) GDPR, provided your inquiry is related to the fulfillment of a contract or 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 inquiries addressed to us (Art. 6 (1) (f) GDPR) or on your consent (Art. 6 (1) (a) GDPR), if requested; consent can be revoked at any time.
The data you enter in the contact form will remain with us until you request its deletion, revoke your consent to storage, or the purpose for storing the data no longer applies (e.g., after your request has been processed). Mandatory legal provisions—in particular, retention periods—remain unaffected.
5. Social media
This website incorporates elements of the social network Facebook. This service is provided by Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland. However, according to Facebook, the collected data is also transferred to the USA and other third countries.
An overview of the Facebook social media elements can be found here: https://developers.facebook.com/docs/plugins/?locale=de_DE .
When the social media element is active, a direct connection is established between your device and the Facebook server. Facebook therefore receives the information that you have visited this website using your IP address. If you click the Facebook “Like” button while logged into your Facebook account, you can link the content of this website to your Facebook profile. This allows Facebook to associate your visit to this website with your user account. We would like to point out that, as the provider of the pages, we have no knowledge of the content of the transmitted data or how Facebook uses it. For more information, see Facebook’s privacy policy at: https://de-de.facebook.com/privacy/explanation .
The use of this service is based on your consent in accordance with Art. 6 (1) (a) GDPR and Section 25 (1) TTDSG. This consent can be revoked at any time.
To the extent that personal data is collected on our website with the help of the tool described here and forwarded to Facebook, we and Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland are jointly responsible for this data processing (Art. 26 GDPR). The joint responsibility is limited exclusively to the collection of the data and its forwarding to Facebook. The processing by Facebook after forwarding is not part of the joint responsibility. Our joint obligations have been set out in a joint processing agreement. The wording of the agreement can be found at: https://www.facebook.com/legal/controller_addendum . According to this agreement, we are responsible for providing data protection information when using the Facebook tool and for implementing the tool on our website in a data protection-compliant manner. Facebook is responsible for the data security of Facebook products. You can assert your data subject rights (e.g. requests for information) regarding the data processed by Facebook directly with Facebook. If you assert your data subject rights with us, we are obliged to forward these to Facebook.
Data transfer to the USA is based on the EU Commission's standard contractual clauses. Details can be found here: https://www.facebook.com/legal/EU_data_transfer_addendum and https://www.facebook.com/policy.php .
The company is certified under the EU-US Data Privacy Framework (DPF). The DPF is an agreement between the European Union and the United States designed to ensure compliance with European data protection standards when processing data in the United States. Every company certified under the DPF is committed to adhering to these data protection standards. Further information is available from the provider at the following link: https://www.dataprivacyframework.gov/s/participant-search/participant-detail?contact=true&id=a2zt0000000GnywAAC&status=Active
Use of the Meta Pixel (formerly Facebook Pixel)
Our website uses the visitor action pixel from Meta Platforms, Inc., 1 Hacker Way, Menlo Park, CA 94025, USA (“Meta”) to measure conversions and optimize advertising measures.
With the help of the meta pixel, Meta is able to define visitors to our website as a target group for the display of personalized advertisements ("meta ads"). This allows us to ensure that our meta ads are only displayed to users who have shown an interest in our online offering or who exhibit certain characteristics (e.g., interest in specific topics or products) determined based on the websites visited. Furthermore, the meta pixel allows us to track the effectiveness of meta ads for statistical and market research purposes by determining whether users were redirected to our website after clicking on a meta ad ("conversion measurement").
Data collection and processing by Meta
When you visit our website, a direct connection is established between your browser and a Meta server via the pixel. This may include, among other things, your IP address, browser information, the website visited, and the time of access, and may be assigned to Meta accounts. This data processing is carried out by Meta. We have no influence on the scope and further use of the data by Meta.
Use of Meta Custom Audiences & Conversions API
Additionally, our website may use the "Custom Audiences" feature and the Meta Conversions API to securely record user interactions on the server and use them for targeted advertising. Data may also be processed independently of cookies.
Legal basis & consent
Your data will be processed exclusively on the basis of your express consent in accordance with Art. 6 (1) (a) GDPR . You grant this consent via our consent management tool when you first visit our website. You can revoke your consent at any time using the tool.
Further information
For further information on data processing by Meta, please see Meta’s privacy policy at:
https://www.facebook.com/privacy/policy/
6. Analysis tools and advertising
IONOS WebAnalytics
This website uses the analytics services of IONOS WebAnalytics (hereinafter: IONOS). The provider is 1&1 IONOS SE, Elgendorfer Straße 57, D – 56410 Montabaur. IONOS' analytics may include, among other things, visitor numbers and behavior (e.g., number of page views, duration of a website visit, bounce rates), visitor sources (i.e., which page the visitor comes from), visitor locations, and technical data (browser and operating system versions). For this purpose, IONOS stores the following data in particular:
Referrer (previously visited website)
requested website or file
Browser type and version
operating system used
device type used
Time of access
IP address in anonymized form (used only to determine the location of access)
According to IONOS, data collection is completely anonymous, meaning it cannot be traced back to individual users. IONOS WebAnalytics does not store cookies.
The data is stored and analyzed on the basis of Art. 6 (1) (f) GDPR. The website operator has a legitimate interest in the statistical analysis of user behavior in order to optimize both its website and its advertising. If consent has been requested, processing is carried out exclusively on the basis of Art. 6 (1) (a) GDPR and Section 25 (1) TTDSG, insofar as the consent includes the storage of cookies or access to information on the user's device (e.g., device fingerprinting) within the meaning of the TTDSG. Consent can be revoked at any time.
For further information on data collection and processing by IONOS WebAnalytics, please refer to the IONOS privacy policy at the following link: https://www.ionos.de/terms-gtc/datenschutzerklaerung/
Order processing
We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract required by data protection law, which guarantees that the personal data of our website visitors will only be processed in accordance with our instructions and in compliance with the GDPR.
7. Newsletter
Newsletter data
If you would like to receive the newsletter offered on the website, we require an email address from you as well as information that allows us to verify that you are the owner of the specified email address and that you agree to receive the newsletter. No further data is collected or is collected only on a voluntary basis. We use this data exclusively to send the requested information and do not share it with third parties.
The data entered into the newsletter registration form will be processed exclusively on the basis of your consent (Art. 6 (1) (a) GDPR). You can revoke your consent to the storage of your data, your email address, and their use for sending the newsletter at any time, for example, via the "unsubscribe" link in the newsletter. The legality of the data processing operations already carried out remains unaffected by the revocation.
The data you provide us with for the purpose of subscribing to the newsletter will be stored by us or the newsletter service provider until you unsubscribe from the newsletter. The data will be deleted from the newsletter distribution list after you unsubscribe from the newsletter or if the purpose no longer applies. We reserve the right to delete or block email addresses from our newsletter distribution list at our own discretion within the scope of our legitimate interest pursuant to Art. 6 (1) (f) GDPR.
Data stored by us for other purposes remains unaffected.
After you unsubscribe from the newsletter mailing list, your email address may be stored on a blacklist by us or the newsletter service provider if this is necessary to prevent future mailings. The data from the blacklist will be used solely for this purpose and will not be merged with other data. This serves both your interest and our interest in complying with legal requirements when sending newsletters (legitimate interest within the meaning of Art. 6 (1) (f) GDPR). Storage on the blacklist is not time-limited. You can object to storage if your interests outweigh our legitimate interest.
8. Plugins and tools
Google reCAPTCHA
We use "Google reCAPTCHA" (hereinafter "reCAPTCHA") on this website. The provider is Google Ireland Limited ("Google"), Gordon House, Barrow Street, Dublin 4, Ireland.
reCAPTCHA is designed to verify whether the data entered on this website (e.g., in a contact form) is entered by a human or by an automated program. To do this, reCAPTCHA analyzes the behavior of the website visitor based on various characteristics. This analysis begins automatically as soon as the website visitor enters the website. For the analysis, reCAPTCHA evaluates various information (e.g., IP address, time spent on the website, or mouse movements made by the user). The data collected during the analysis is forwarded to Google.
The reCAPTCHA analysis runs entirely in the background. Website visitors are not notified that an analysis is taking place.
The data is stored and analyzed on the basis of Art. 6 (1) (f) GDPR. The website operator has a legitimate interest in protecting its website from abusive automated spying and spam. If consent has been requested, processing is carried out exclusively on the basis of Art. 6 (1) (a) GDPR and Section 25 (1) TTDSG, insofar as the consent includes the storage of cookies or access to information on the user's device (e.g., device fingerprinting) within the meaning of the TTDSG. Consent can be revoked at any time.
For more information about Google reCAPTCHA, please see the Google Privacy Policy and the Google Terms of Service at the following links: https://policies.google.com/privacy?hl=de and https://policies.google.com/terms?hl=de .
The company is certified under the EU-US Data Privacy Framework (DPF). The DPF is an agreement between the European Union and the United States designed to ensure compliance with European data protection standards when processing data in the United States. Every company certified under the DPF is committed to adhering to these data protection standards. Further information is available from the provider at the following link: https://www.dataprivacyframework.gov/s/participant-search/participant-detail?contact=true&id=a2zt000000001L5AAI&status=Active
9. eCommerce and payment providers
Processing of customer and contract data
We collect, process, and use personal customer and contract data to establish, define, and modify our contractual relationships. We collect, process, and use personal data about the use of this website (usage data) only to the extent necessary to enable the user to use the service or to bill them. The legal basis for this is Art. 6 (1) (b) GDPR.
The collected customer data will be deleted after completion of the order or termination of the business relationship and expiration of any applicable statutory retention periods. Statutory retention periods remain unaffected.
10. Own services
Handling applicant data
We offer you the opportunity to apply to us (e.g., by email, post, or online application form). Below, we inform you about the scope, purpose, and use of your personal data collected during the application process. We assure you that the collection, processing, and use of your data will be carried out in compliance with applicable data protection laws and all other legal provisions, and that your data will be treated with strict confidentiality.
Scope and purpose of data collection
If you send us an application, we will process your associated personal data (e.g., contact and communication details, application documents, notes taken during job interviews, etc.) to the extent necessary to decide whether to establish an employment relationship. The legal basis for this is Section 26 of the Federal Data Protection Act (BDSG) under German law (initiation of an employment relationship), Art. 6 (1) (b) GDPR (general contract initiation), and – if you have given your consent – Art. 6 (1) (a) GDPR. This consent can be revoked at any time. Within our company, your personal data will only be passed on to people who are involved in processing your application.
If your application is successful, the data you submit will be stored in our data processing systems on the basis of Section 26 BDSG and Article 6 (1) (b) GDPR for the purpose of implementing the employment relationship.
Data retention period
If we are unable to make you a job offer, if you reject a job offer, or if you withdraw your application, we reserve the right to retain the data you have submitted for up to six months from the end of the application process (rejection or withdrawal of the application) based on our legitimate interests (Art. 6 (1) (f) GDPR). The data will then be deleted and the physical application documents destroyed. Retention is primarily for evidential purposes in the event of a legal dispute. If it is apparent that the data will be required after the six-month period (e.g., due to impending or pending legal proceedings), deletion will only occur when the purpose for further retention no longer applies.
Longer storage may also take place if you have given your consent (Art. 6 (1) (a) GDPR) or if statutory retention periods prevent deletion.
Inclusion in the applicant pool
If we don't offer you a job, you may be included in our applicant pool. If you are accepted, all documents and information from your application will be transferred to the applicant pool so that we can contact you if suitable vacancies arise.
Inclusion in the applicant pool is based solely on your express consent (Art. 6 (1) (a) GDPR). Providing your consent is voluntary and has no connection to the ongoing application process. The data subject may revoke their consent at any time. In this case, the data will be irrevocably deleted from the applicant pool, unless there are legal reasons for retention.
The data from the applicant pool will be irrevocably deleted no later than two years after consent has been given.