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 any data with which you can be personally identified. For detailed information on data protection, please refer to 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 section “Information on the Responsible Party” in this privacy policy.

How Do We Collect your Data?

Your data is collected, on the one hand, by you providing it to us. This may include, for example, data you enter into a contact form.

Other data is collected automatically or with your consent by our IT systems when you visit the website. This primarily includes technical data (e.g., internet browser, operating system, or time of page view). This data is collected automatically as soon as you enter 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 at any time to receive information free of charge about the origin, recipient, and purpose of your stored personal data. You also have the right to request the correction or deletion of this data. If you have given consent to data processing, you can revoke this consent at any time for the future. Furthermore, you have the right to request the restriction of the processing of your personal data under certain circumstances. You also have the right to lodge a complaint with the competent supervisory authority.

For this and other questions on the subject of data protection, you can contact us at any time.

Analysis Tools and Tools from Third-Party Providers

When you visit this website, your surfing behavior can be statistically evaluated. This is primarily done with so-called analysis programs.

Detailed information on these analysis programs can be found in the following privacy policy.

2. Hosting and Content Delivery Networks (CDN)

External Hosting

This website is hosted by an external service provider (host). The personal data collected on this website is stored on the host’s servers. This may include IP addresses, contact requests, meta and communication data, contract data, contact details, names, website access and other data generated via a website.

The host is used for the purpose of fulfilling the contract with our potential and existing customers (Art. 6 para. 1 lit. b GDPR) and in the interest of a secure, fast and efficient provision of our online offer by a professional provider (Art. 6 para. 1 lit. f GDPR).

Our host will only process your data to the extent necessary to fulfill its service obligations and will follow our instructions with regard to this data.

We use the following host:

Hetzner Online GmbH
Industriestr. 25
91710 Gunzenhausen
Germany

Conclusion of a Contract for Order Processing

In order to guarantee data protection-compliant processing, we have concluded a contract for order processing with our host.

3. General information and mandatory information

Privacy

The operators of these pages take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with statutory data protection regulations and this privacy policy.

When you use this website, various personal data is collected. Personal data is data with which you can be personally identified. This privacy policy explains what data we collect and what we use it for. It also explains how and for what purpose this happens.

We would like to point out that data transmission over the Internet (e.g., when communicating by email) can have security vulnerabilities. Complete protection of data against access by third parties is not possible.

Information on the Responsible Body

The responsible body for data processing on this website is:

SpineMED® Innovative Medizintechnik GmbH
Wilhelm-Wagenfeld-Straße 4
80807 Munich

Telephone: 089.890 63 65 12
E-mail: c.glammert@spine-med.de

The responsible party 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, email addresses, etc.).

Storage Period

Unless a more specific storage period has been specified within 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, provided that we have no other legally permissible reasons for storing your personal data (e.g. tax or commercial law retention periods); in the latter case, the deletion will take place after these reasons no longer apply.

Information on Data Transfer to the USA and other Third Countries

Among other things, we use tools from companies based in the USA or other third countries that are not secure under data protection law. If these tools are active, your personal data may be transferred to these third countries and processed there. We would like to point out that a level of data protection comparable to that in the EU cannot be guaranteed in these countries. For example, US companies are obliged to hand over personal data to security authorities without you as the data subject being able to take legal action against this. It cannot therefore be ruled out that US authorities (e.g., intelligence services) may process, evaluate, and permanently store your data located on US servers for surveillance purposes. We have no influence on these processing activities.

Revocation of your Consent to Data Processing

Many data processing operations are only possible with your express consent. You can revoke consent already given at any time. The legality of the data processing carried out until the revocation remains unaffected by the revocation.

Right to Object to Data Collection in Special Cases and to Direct Advertising (Art. 21 GDPR)

IF DATA PROCESSING IS CARRIED OUT ON THE BASIS OF ART. 6 ABS. 1 LIT. 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 AFFECTED PERSONAL DATA UNLESS WE CAN PROVE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING THAT OUTWEIGH YOUR INTERESTS, RIGHTS AND FREEDOMS OR THE PROCESSING SERVES TO ASSERT, EXERCISE OR DEFEND LEGAL CLAIMS (OBJECTION ACCORDING TO ART. 21 ABS. 1 GDPR).

IF YOUR PERSONAL DATA IS PROCESSED FOR THE PURPOSE OF DIRECT MARKETING, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF PERSONAL DATA CONCERNING YOU FOR THE PURPOSE OF SUCH MARKETING; 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 THE PURPOSE OF DIRECT MARKETING (OBJECTION PURSUANT TO ART. 21 PARA. 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, their place of work or the place of the alleged violation. The right to lodge a complaint exists without prejudice to other administrative or judicial remedies.

Right to Data Portability

You have the right to have data that we process automatically on the basis of 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 take place if it is technically feasible.

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 requests that you send to us as the site operator. You can recognize an encrypted connection by the fact that the address line of the browser changes from “http://” to “https://” and by the lock symbol in your browser line.

If SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.

Information, Deletion and Correction

Within the framework of the applicable legal provisions, you have the right at any time to free information about your stored personal data, its origin and recipients and the purpose of the data processing and, if applicable, a right to correction or deletion of this data. You can contact us at any time with regard to this as well as for further questions on the subject of 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. The right to restriction of processing exists in the following cases:

If you dispute the accuracy of your personal data stored by us, we usually need time to verify this. For the duration of the review, you have the right to request the restriction of the processing of your personal data.
If the processing of your personal data was/is unlawful, you can request the restriction of data processing instead of erasure.
If we no longer need your personal data, but you require it for the establishment, exercise, or defense of legal claims, you have the right to request the restriction of the processing of your personal data instead of erasure.
If you have lodged an objection pursuant to Art. 21 para. 1 GDPR, a balancing of your interests and ours must be carried out. As long as it has not yet been determined whose interests prevail, you have the right to request the restriction of the processing of your personal data.

If you have restricted the processing of your personal data, these data – apart from their storage – may only be processed with your consent or for the establishment, exercise, or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or a Member State.

Objection to Advertising Emails

The use of contact data published within the scope of the imprint obligation for sending unsolicited advertising and information materials is hereby objected to. The operators of the pages expressly reserve the right to take legal action in the event of unsolicited sending of advertising information, such as spam e-mails.

4. Data collection on this website

Cookie Consent with Borlabs Cookie

Our website uses the cookie consent technology from Borlabs Cookie to obtain your consent to the storage of certain cookies in your browser and to document this in accordance with data protection regulations. The provider of this technology is Borlabs – Benjamin A. Bornschein, Rübenkamp 32, 22305 Hamburg (hereinafter Borlabs).

When you enter our website, a Borlabs cookie is stored in your browser, in which the consents you have given or the revocation of these consents are stored. This data is not passed on to the provider of Borlabs Cookie.

The data collected will be stored until you ask us to delete it or delete the Borlabs cookie yourself, or until the purpose for data storage no longer applies. Mandatory statutory retention periods remain unaffected. Details on data processing by Borlabs Cookie can be found at https://de.borlabs.io/kb/welche-daten-speichert-borlabs-cookie/.

The Borlabs cookie consent technology is used to obtain the legally required consents for the use of cookies. The legal basis for this is Art. 6 para. 1 lit. c GDPR.

Server Log Files

The provider of the pages automatically collects and stores information in so-called server log files, which your browser automatically transmits to us. These are:

Browser type and browser version
Operating system used
Referrer URL
Hostname of the accessing computer
Time of server request
IP address

This data is not merged with other data sources.

The collection of this data is based on Art. 6 para. 1 lit. f GDPR. The website operator has a legitimate interest in the technically flawless presentation and optimization of its website – server log files must be recorded for this purpose.

Inquiry by Email, Telephone, or Fax

If you contact us by email, telephone, or fax, your inquiry, including all personal data resulting therefrom (name, inquiry), will be stored and processed by us for the purpose of handling your request. We will not share this data without your consent.

The processing of this data is based on Art. 6 para. 1 lit. b GDPR, provided that your request is related to the fulfillment of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective processing of the requests addressed to us (Art. 6 para. 1 lit. f GDPR) or on your consent (Art. 6 para. 1 lit. a GDPR) if this has been requested.

The data you send us via contact inquiries will remain with us until you request its deletion, revoke your consent for storage, or the purpose for data storage ceases to apply (e.g., after your request has been processed). Mandatory legal provisions – especially legal retention periods – remain unaffected.

Hubspot CRM

We use Hubspot CRM on this website. The provider is Hubspot Inc. 25 Street, Cambridge, MA 02141 USA (hereinafter Hubspot CRM).

Hubspot CRM enables us, among other things, to manage existing and potential customers as well as customer contacts. With the help of Hubspot CRM, we are able to record, sort and analyze customer interactions via e-mail, social media or telephone across various channels. The personal data collected in this way can be evaluated and used for communication with the potential customer or for marketing measures (e.g. newsletter mailings). With Hubspot CRM, we are also able to record and analyze the user behavior of our contacts on our website.

The use of Hubspot CRM is based on Art. 6 para. 1 lit. f GDPR. The website operator has a legitimate interest in the most efficient customer management and customer communication possible. If a corresponding consent has been requested, the processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a GDPR; the consent can be revoked at any time.

For details, please refer to Hubspot’s privacy policy: https://legal.hubspot.com/de/privacy-policy.

The data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here: https://www.hubspot.de/data-privacy/privacy-shield.

Contract for Order Processing

We have concluded a contract for order processing with Hubspot CRM. This is a contract required by data protection law, which ensures that Hubspot CRM processes the personal data of our website visitors only in accordance with our instructions and in compliance with the GDPR.

5. Analysis tools and advertising

Google Tag Manager

We use Google Tag Manager. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

Google Tag Manager is a tool that allows us to integrate tracking or statistics tools and other technologies into our website. Google Tag Manager itself does not create user profiles, store cookies, or perform independent analyses. It merely serves to manage and deploy the tools integrated through it. However, Google Tag Manager collects your IP address, which can also be transferred to Google’s parent company in the United States.

The use of Google Tag Manager is based on Art. 6 para. 1 lit. f GDPR. The website operator has a legitimate interest in the quick and uncomplicated integration and management of various tools on its website. If a corresponding consent has been requested, the processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a GDPR; the consent can be revoked at any time.

Google Analytics

This website uses functions of the web analytics service Google Analytics. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

Google Analytics enables the website operator to analyze the behavior of website visitors. The website operator receives various usage data, such as page views, length of stay, operating systems used and the origin of the user. This data may be summarized by Google in a profile that is assigned to the respective user or their end device.

Google Analytics uses technologies that enable user recognition for the purpose of analyzing user behavior (e.g., cookies or device fingerprinting). The information collected by Google about the use of this website is usually transferred to a Google server in the USA and stored there.

The use of this analysis tool is based on 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. If a corresponding consent has been requested (e.g. consent to the storage of cookies), the processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a GDPR; the consent can be revoked at any time.

The data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here: https://privacy.google.com/businesses/controllerterms/mccs/.

IP Anonymization

We have activated the IP anonymization function on this website. This means that your IP address will be shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area before transmission to the USA. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA 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 transmitted by your browser as part of Google Analytics will not be merged with other Google data.

Browser Plugin

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

More information on how Google Analytics handles user data can be found in Google’s privacy policy: https://support.google.com/analytics/answer/6004245?hl=de.

Data Processing Agreement

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

Demographic Features in Google Analytics

This website uses the “demographic features” function of Google Analytics to display relevant advertisements to website visitors within the Google advertising network. This allows for the creation of reports that contain statements about the age, gender, and interests of page visitors. This data originates from interest-based advertising by Google as well as from third-party visitor data. This data cannot be assigned to a specific person. You can deactivate this function at any time via the ad settings in your Google account or generally prohibit the collection of your data by Google Analytics as described in the “Objection to Data Collection” section.

6. Plugins and Tools

Google Maps

This site uses the Google Maps map service. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

To use the functions of Google Maps, it is necessary to store your IP address. This information is usually transferred to a Google server in the USA and stored there. The provider of this site has no influence on this data transfer. When Google Maps is activated, Google may use Google Web Fonts for the purpose of uniform font display. When you call up Google Maps, your browser loads the required web fonts into its browser cache in order to display texts and fonts correctly.

The use of Google Maps is in the interest of an appealing presentation of our online offers and easy findability of the places specified by us on the website. This represents a legitimate interest within the meaning of Art. 6 para. 1 lit. f GDPR. If a corresponding consent has been requested, the processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a GDPR; the consent can be revoked at any time.

The data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here: https://privacy.google.com/businesses/gdprcontrollerterms/ and https://privacy.google.com/businesses/gdprcontrollerterms/sccs/.

More information on how user data is handled can be found in Google’s privacy policy: https://policies.google.com/privacy?hl=de.

Wordfence

We have integrated Wordfence on this website. The provider is Defiant Inc., Defiant, Inc., 800 5th Ave Ste 4100, Seattle, WA 98104, USA (hereinafter Wordfence).

Wordfence serves to protect our website from unwanted access or malicious cyber attacks. For this purpose, our website establishes a permanent connection to the Wordfence servers so that Wordfence can compare its databases with the accesses made on our website and block them if necessary.

The use of Wordfence is based on Art. 6 para. 1 lit. f GDPR. The website operator has a legitimate interest in the most effective protection of its website against cyber attacks. If a corresponding consent has been requested, the processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a GDPR; the consent can be revoked at any time.

The data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here: https://www.wordfence.com/help/general-data-protection-regulation/.

Conclusion of a Contract for Order Processing

We have concluded a contract for order processing with Wordfence. This is a contract required by data protection law, which ensures that Wordfence processes the personal data of our website visitors only in accordance with our instructions and in compliance with the GDPR.