Data Policy

Responsible person:

Spielfeld Digital Hub GmbH
Skalitzer St. 85 – 86 – 10997 Berlin – Germany
Phone: 030 – 399 27 38 01
E-mail: info[at]spielfeld.com

This data protection statement describes how Spielfeld Digital Hub GmbH (hereinafter referred to as “Spielfeld”) collects, uses, stores, distributes and protects your personal data. If you have any questions regarding data protection which are not answered in this data protection declaration or if you would like further information, please do not hesitate to contact us at dataofficer[at]spielfeld.com.

Date of the last update of this policy:  30.07.2018

In case that changes to this privacy policy are necessary, we will post the amended statement and the effective date of the amended statement on this website. Please take notice of them regulary. We only will change concerning a consent given by you by obtaining the consent again. This data protection declaration is valid from 25.05.2018.

1. General information about data processing

We take the protection of your personal data very seriously. This is why we process them exclusively in accordance with the General Data Protection Regulation (GDPR) and other national data protection laws. This is necessary to provide a functional website. In addition, we can make our content and services available to you.

Personal data will only be processed if you have given your consent. An exception to this only takes place if for real reasons no consent can be obtained and legal regulations permit data processing.

The data will only be processed to the extent that it is lawful. Legality is given if at least one condition specified in Art. 6 para. 1 GDPR is fulfilled. We delete your data as soon as the purpose of storage ceases the application or a period prescribed by law (usually 7 days) has expired. You have the possibility to object to data processing with effect for the future at any time. For this purpose, please send us a written declaration of revocation post or by e-mail.

Our service is not directed at children under 13 years of age and we do not knowingly collect data from people under 13 years of age. If we get to know that we got data about a person younger than 13 years, we will not process or retain it without the consent of the parent or guardian. However, if we have ever processed a child’s data, we will make every effort to remove this information from our systems.

2. Logfiles

When you visit our website, our system automatically collects data and information from your computer system. The following data is collected:

  • Date and time of access,
  • Name and URL of the a file,
  • the browser used and, if applicable, the operating system of your computer as well as the name of your access provider
    This data is stored in the log files of our system. This data is not stored together with other personal data of the user.

The data is stored in the log files to ensure the functionality of our website. In addition, we can use the data to optimize our website and ensure the security of our information technology systems. We do not use them for marketing purposes.

Our legitimate interest in data processing pursuant to Art. 6 para. 1 lit. f GDPR also lies in these purposes. The stored data will be deleted as soon as their purpose is fulfilled. If the data for the provision of the website is collected, its purpose is achieved when the session is terminated. Since the collection of data for the provision of the website and the storage of data in log files is absolutely essential for the operation of the website, there is no possibility of objection for you.

3. Cookies

We use so-called “cookies” on our website. These are text files that are stored on your mobile device. Some of the cookies we use, so-called session cookies, are deleted immediately when you close your browser, i.e. when you end the session. Other cookies are still stored on your terminal and enable us and our third party providers (see 6. and 7.) to recognize your browser the next time you visit our website (persistent cookies). Set cookies are processed to the individual extent and collect data such as:

  • Browser type/version
  • Operating system
  • Referrer URL
  • Time and date of the server request

Persistent cookies are deleted automatically after a specified period. Cookies are used to make your visit to our website attractive and to enable the use of certain functions. If the cookies we set process personal data, the processing is in accordance with Art. 6 Para. 1 letter b GDPR either for contractual purposes or in accordance with Art. 6 Para. 1 letter f GDPR to protect our legitimate interests of a user-friendly website is lawful.

Under (6, 7 and 8) you can find out about the type and extent of data processing via the cookies collected from third party providers.

To prevent cookies from being set, you can set your browser in a way that you are informed about the setting of cookies and can decide individually whether to accept them or generally exclude the acceptance of cookies in certain cases. How to set the browser is different for each browser. You will find a description of the cookie settings for the respective browser under the following links:

  • Internet Explorer: http://windows.microsoft.com/de-DE/windows-vista/Block-or-allow-cookies
  • Firefox: https://support.mozilla.org/de/kb/cookies-erlauben-und-ablehnen
  • Chrome: http://support.google.com/chrome/bin/answer.py?hl=en&hlrm=en&answer=95647
  • Safari: https://support.apple.com/kb/ph21411?locale=en_EN
  • Opera: http://help.opera.com/Windows/10.20/de/cookies.html

Please note that the functionality of our website may be limited if cookies are not accepted.

4. Newsletter

On our website you have the possibility to subscribe to a free newsletter. When registering for this newsletter, the following data will be collected:

  • First and last name
  • Email address
  • Trade name
  • Job position

The following data is collected during the registration process:

  • IP address of the called computer
  • Date and time of registration
4.1. Mailchimp

The newsletter is sent via “MailChimp”, a newsletter distribution platform of the US provider The Rocket Science Group, LLC, 675 Ponce De Leon Ave NE Suite 5000, Atlanta, GA 30308, USA.

The data of the newsletter recipients described above, which are collected in the context of the newsletter dispatch, are stored on the servers of MailChimp in the USA. MailChimp uses this information to send and evaluate the newsletter on our behalf. Furthermore, MailChimp can use this data according to its own information to optimize or improve its own services, e.g. to technically optimize the sending and presentation of the newsletter or for economic purposes, in order to determine from which countries the recipients come. However, MailChimp does not use the data of our newsletter recipients to write them down itself. The data will not be passed on to third parties.

The privacy policy of MailChimp can be found here: https://mailchimp.com/legal/privacy

4.1.1. Statistical surveys and analyses

The newsletters contain “web-beacon”. This is a pixel-sized file that is retrieved from the MailChimp server when the newsletter is opened. Within the scope of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and time of retrieval are initially collected. This information is used to technically improve the services based on the technical data or the target groups and their reading behaviour based on their retrieval locations (which can be determined using the IP address) or access times.

The statistical surveys also include determining whether the newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to the individual newsletter recipients. However, it is neither our endeavour, nor that of MailChimp, to observe individual users. The evaluations serve us much more to recognize the reading habits of our users and to adapt our contents to them or to send different contents according to the interests of our users.

After you have registered for the newsletter and given your consent accordingly, the data processing is carried out legally in accordance with Art. 6 para. 1 lit. a GDPR. The purpose of collecting your e-mail address is to send you the newsletter. The company name and job position are used to personalize the newsletter content. The collection of other personal data (first and last name, IP address, etc.) serves to prevent misuse of the services or the e-mail address used. These data are deleted as soon as the purpose of their collection has been achieved. In principle, this data is stored as long as the subscription to the newsletter is active. All other data collected during the registration process will be deleted after a period of 7 days. You can cancel your subscription to the newsletter at any time by following the link provided in the newsletter. By doing so, you also contradict the data processing within the scope of the newsletter.

5. Email contact

There is a contact form on our website which you can use to contact us electronically. If you take advantage of this option, the data entered in the input mask will be transmitted to us and processed. This data is:

  • Name
  • Email address
  • Other personal data entered in the message text field

In the process of sending this message, the following data is stored:

  • IP address
  • Date and time of registration

Your consent is obtained for the processing of the data within the scope of the sending process and reference is made to this data protection declaration.

Alternatively, you can contact us via the following e-mail addresses:

  • info[at]spielfeld.com
  • tobias[at]spielfeld.com
  • jobs[at]spielfeld.com
  • office[at]spielfeld.com
  • camp[at]spielfeld.com
  • dataofficer[at]spielfeld.com
  • events[at]spielfeld.com
  • finance[at]spielfeld.com
  • digitalbootcamp[at]spielfeld.com

In this case we process and store the personal data transmitted by the e-mail. This will be your email address and any other information you provide. Such data processing is necessary for the processing of the conversation. Data processing is based on our legitimate interest within the meaning of Art. 6 para. 1 lit. f) GDPR and is therefore legal, provided that you are not unreasonably restricted in your rights as a result. If the establishment of contact serves the conclusion of a contract, the processing according to Art. 6 Abs. 1 lit. b) GDPR is legal. If you provide further data without being asked, the processing is based on your consent within the meaning of Art. 6 para. 1 lit. a) GDPR, which will be deleted as soon as the conversation is over and there is no further purpose for storage. The conversation is terminated when it can be inferred from the circumstances that the facts in question have been finally clarified. All other data transmitted by the sending process will be deleted after a period of 7 days at the latest. The data can be processed by a written declaration of revocation of data processing to dataofficer[at]spielfeld.com.

6. Google Analytics

This website uses functions of the web analytics service Google Analytics. Provider is Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA.

Google Analytics uses so-called “cookies”. These are text files that are stored on your computer and that allow analyzing your usage of our website. The information generated by the cookie about your use of this website such as

a. Browser type / version,
b. Uses the operating system
c. Referrer URL (the previously visited page),
d. Host name of the accessing computer (IP address),
e. Time of the server request

are usually transmitted to a Google server in the US and stored there. Google Analytics cookies are stored on the basis of Art. 6 para. 1 lit. f GDPR. The website operator has a legitimate interest in analyzing user behavior in order to optimize both its website and its advertising.


IP anonymization

We have activated the function IP anonymization on this website. As a result, your IP address will be truncated by Google within member states of the European Union or other parties to the Agreement on the European Economic Area prior to transmission to the United States. Only in exceptional cases the full IP address will 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 usage to the website operator. The IP address provided by Google Analytics as part of Google Analytics will not be merged with other Google data.

Browser plugin

You can prevent the storage of cookies by a corresponding setting of your browser software; however, please note that if you do this, you may not be able to use all the features of this website to the fullest extent. 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 the browser plug-in available under the following link and install: https://tools.google.com/dlpage/gaoptout?hl=en.

Opposition to data collection

You can prevent the collection of your data by Google Analytics by clicking on the following link. An opt-out cookie will be set which prevents the collection of your data on future visits to this website: disable Google Analytics. For more information on how to handle user data on Google Analytics, please refer to the Google Privacy Policy: https://support.google.com/analytics/answer/6004245?hl=en.

Order processing

We have entered into a contract data processing agreement with Google and fully implement the strict requirements of the German data protection authorities when using Google Analytics.

7. Social media plug-ins

We use social networks on our website. Here you can see which company processes data in this context. Data processing is based on our legitimate interest pursuant to Art. 6 para. 1 lit. f) GDPR.

7.1. Facebook

Our website contains plugins from Facebook, 1601 South California Avenue, Palo Alto, CA 94304, USA. Facebook is a social network. The respective plugin can be recognized by the Facebook logo or the “Like Me button”. You can view the complete overview of all Facebook plugins under the following link: http://developers.facebook.com/docs/plugins/

As soon as you visit our website, the Facebook plug-in establishes a direct connection between your Internet browser and the Facebook servers. This way, Facebook is informed that your IP address has been used to visit our website. If you are logged in to Facebook, you can use the “Like Me” button to link to the relevant content on our website in your Facebook profile. Facebook will then be able to associate your visit to our website with your Facebook account. We, as the provider of our website, are not informed by Facebook about the content of the transmitted data or the use of the data. You can find further information under the following link: http://de-de.facebook.com/policy.php

If you are a member of Facebook but do not want Facebook to receive information about you through our website and connect to your membership information, you must log out of Facebook before visiting our website.

7.2. Twitter

Our website contains functions of Twitter Inc, 795 Folsom Street, Suite 600, San Francisco, CA 94107, USA. If you use Twitter and especially the “Re-Tweet” function, Twitter links your Twitter account to the websites you visit frequently. This will be announced to other users on Twitter, especially to your followers. This is also the way to transfer data to Twitter. We, as the provider of our website, are not informed by Twitter about the content of the transmitted data or the use of the data. You can find further information under the following link: http://twitter.com/privacy

Please note, however, that you can change your privacy settings on Twitter in your account settings there at http://twitter.com/account/settings

7.3. LinkedIn

You will find on our website plugins of the social network LinkedIn and LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA (hereafter referred to as “LinkedIn”). You can recognize the LinkedIn plugins by the corresponding logo or the “Recommend” button. Please note that the plugin establishes a connection between your Internet browser and the LinkedIn server when you visit our website. LinkedIn is thus informed that our website has been visited with your IP address. If you click the “Recommend-Button” of LinkedIn and are logged into your LinkedIn account at the same time, you have the possibility to link content from our website on your LinkedIn profile page. Then you enable LinkedIn to assign your visit to our website to you or your user account. You must know that we have no knowledge of the content of the transmitted data and its use by LinkedIn. Please contact LinkedIn for more details on data collection, your legal options and recruitment options. These are made available to you at http://www.linkedin.com/static?key=privacy_policy&trk=hb_ft_priv.

Information about Linkedin LeadGen Forms.

7.4. Splashthat “Academy”

The “Academy” button will take you to the https://spielfeldacademy.splashthat.com website. Via this link we market our workshops. No data is collected when using the link.

For more details, please visit https://splashthat.com/privacy .

8. Disclosure of data by us

We disclose personal information to comply with legal obligations, investigate complaints about offers or content that infringe the rights of third parties, and protect the rights, property or safety of others. This information will only be disclosed in accordance with the applicable laws. As stated above, we will not disclose your personal data to third parties for their marketing purposes without your express consent.

We may also disclose your personal information to law enforcement or regulatory authorities or authorized third parties on the basis of a request for information in connection with a criminal investigation or suspicion of a criminal offence, an unlawful act or other actions that may give rise to legal liability for us, you or another user. In such cases, we will disclose information necessary for the investigation, such as name, city, zip code, telephone number, e-mail address, previous user names, IP address, fraud complaints and offer overview.

9. Data subject rights

The applicable data protection law grants users as data subject to the controller comprehensive data subject rights (information and intervention rights):

9.1. Right to confirmation, Art. 15 para. 1 sentence 1 GDPR

The data subject has the right to ask the controller for a confirmation of the processing of the personal data concerned.

9.2. Right to information, Art. 15 para. 1 sentence 2 GDPR

If the personal data of the data subject are processed, they have the right to inform about this personal data and to the following information:

a. the processing purposes;
b. the categories of personal data being processed;
c. the recipients or categories of recipients to whom the personal data have been disclosed or are still being disclosed, in particular to recipients in third countries or to international organizations;
d. if possible, the planned duration for which the personal data are stored or, if this is not possible, the criteria for determining that duration;
e. the existence of a right to rectification or erasure of the personal data concerning them, or to the restriction of processing by the controller or a right to object to such processing;
f. the existence of a right of appeal to a supervisory authority;
g. if the personal data are not collected from the data subject, all available information on the source of the data;
h. the existence of automated decision-making including profiling as referred to in Article 22 (1) and (4) and, at least in these cases, meaningful information about the logic involved, and the scope and intended impact of such processing on the data subject.

9.3. Right to correction and completion, Art. 16 GDPR

The data subject has the right to demand from the person responsible without delay the correction of incorrect personal data concerning him.

In consideration of the purposes of the processing, the data subject has the right to request the completion of incomplete personal data, including by means of a supplementary statement.

9.4. Right to cancellation (right to be forgotten), Art. 17 GDPR

The data subject has the right to require the person responsible to delete personal data concerning him or her without delay, and the person responsible is obliged to delete personal data immediately, if one of the following reasons applies:

a. The personal data are no longer necessary for the purposes for which they were collected or otherwise processed.
b. The data subject withdraws the consent on which the processing referred to in Art. 6 para. 1 lit. a or Art. 9 para. 2 lit. a GDPRwas based and lacks any other legal basis for the processing.
c. The data subject shall object to the processing in accordance with Art. 21 para. 1 GDPR and there are no legitimate grounds for processing, or the data subject shall submit, in accordance with Art. 21 para. 2 GDPR.
d. Objection to the processing.
e. The personal data were processed unlawfully.
f. The erasure of personal data is necessary to fulfill a legal obligation under Union or national law to which the controller is subject.
g. The personal data were collected in relation to information society services offered in accordance with Art. 8 para. 1 GDPR.

However, the above does not apply if the processing is done for legal purposes.

9.5. Right to restriction of processing, Art. 18 GDPR

The data subject has the right to require the controller to restrict the processing if one of the following conditions is met:

a. the accuracy of the personal data is disputed by the data subject for a period allowing the controller to verify the accuracy of the personal data;
b. the processing is unlawful and the data subject refuses to delete the personal data and instead requests the restriction of the use of the personal data;
c. the controller no longer needs the personal data for the purposes of the processing, but the data subject requires them to assert, exercise or defend legal claims; or
d. the person concerned has lodged an objection to the processing referred to in Art. 21 para. 1 GDPR, pending determination of whether the legitimate grounds of the controller prevail over those of the data subject.

Therefore, if the processing has been restricted, these personal data may only be stored with the consent of the data subject or for the purpose of asserting, exercising or defending legal claims or protecting the rights of another natural or legal person or for important public interest Union or a Member State.

An affected person who has restricted processing will be notified by the controller before the restriction is lifted.

9.6. Right to Data Transferability, Art. 20 GDPR

The data subject has the right to receive personal data relating to him or her provided to a controller in a structured, common and machine – readable format and has the right to transfer that information to another person, without interference from the controller to whom personal data provided if:

a. the processing is based on a consent in accordance with Art. 6 para. 1 lit. a GDPR or Art. 9 para. 2 lit. a GDPR or on a contract pursuant to Art. 6 para. 1 lit. b GDPR; and
b. the processing is done using automated procedures.

In exercising their right to data portability, the data subject has the right to obtain the personal data to be transferred directly from one controller to another responsible party where technically feasible.

9.7. Right to objection, Art. 21 GDPR

The data subject has the right at any time, for reasons arising from his / her special situation, against the processing of personal data relating to him / her which, pursuant to Art. 6 para. 1 lit. e and f GDPR, to object; this also applies to profiling based on these provisions. The controller no longer processes the personal data unless he can demonstrate compelling legitimate grounds for processing that outweigh the interests, rights and freedoms of the data subject, or the processing is for the purpose of enforcing, pursuing or defending legal claims.

9.8. Right to revoke the consent granted, Art. 7 para. 3 GDPR

The data subject has the right to withdraw their consent at any time. The revocation of consent does not affect the legality of the processing carried out on the basis of the consent until the revocation. The data subject will be informed before the consent is given. The revocation of consent must be as simple as the granting of consent.

9.9. Right to appeal, Art. 77 para. 1 GDPR

Without prejudice to any other administrative or judicial remedy, any data subject shall have the right to lodge a complaint with a supervisory authority, in particular in the Member State of the habitual residence, place of work or place of alleged infringement, if the data subject considers that the processing concerns him / her personal data breaches this Regulation.

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