Privacy Policy

01Controller

SpHHere B.V., Keizersgracht 520 H, 1017 EK Amsterdam, The Netherlands. Represented by Johannes Hammerstein, Managing Director. Phone +31 6 41081205, email info@sphhere.com.

For all questions about data protection, contact us at info@sphhere.com.

02Hosting

This website is hosted by ALL-INKL.COM – Neue Medien Münnich, owner René Münnich, Hauptstraße 68, 02742 Friedersdorf, Germany. When you visit the website, ALL-INKL processes the data needed to deliver it to you on our behalf, under a data processing agreement pursuant to Art. 28 GDPR.

The website is hosted on servers located in Germany. Your data is therefore processed within the European Union and is not transferred to third countries.

03Server log files

Each time you access the website, the following data is automatically collected: IP address, date and time of access, pages viewed, referring URL, browser type and version, and operating system.

This data is used only to deliver the website, keep it secure and fix technical errors. The legal basis is our legitimate interest in a secure and functioning website (Art. 6(1)(f) GDPR). Log data is not combined with other data sources and is deleted once it is no longer needed for these purposes.

04Contacting us

If you use the contact form, it opens your own email program with your message pre-filled. No data is transmitted to us until you send the email yourself.

When you email or call us, we process the details you provide (such as name, email address, company and message) to handle your enquiry. The legal basis is the performance of pre-contractual measures (Art. 6(1)(b) GDPR) or our legitimate interest in responding to enquiries (Art. 6(1)(f) GDPR). We delete this data once your enquiry has been dealt with, unless statutory retention obligations apply, such as the seven-year retention period for business records under Dutch law.

05Cookies, analytics and tracking

We do not use cookies or similar technologies for analytics, advertising or tracking, and we do not create user profiles. Any cookies set are strictly necessary for the technical operation and security of the website (Art. 6(1)(f) GDPR and § 25(2) TDDDG).

06Fonts, scripts and media

All fonts, scripts, images and videos on this website are served from our own hosting. No connection is made to third-party servers such as Google Fonts or public code libraries when you load a page.

07Links to other websites

This website links to external sites such as LinkedIn and our partners’ websites. Data is only transmitted to these providers if you click a link. Their own privacy policies then apply.

08Recipients of data

We share personal data only with our hosting provider as described above and, where necessary to answer your enquiry, within SpHHere and with our advisors who are bound by confidentiality. We do not sell personal data.

09Your rights

You have the right to access your personal data (Art. 15 GDPR), to have it corrected (Art. 16), erased (Art. 17) or its processing restricted (Art. 18), to data portability (Art. 20), and to object to processing based on legitimate interests (Art. 21). Where processing is based on consent, you may withdraw it at any time with effect for the future.

To exercise these rights, email info@sphhere.com.

10Right to lodge a complaint

You may lodge a complaint with a data protection supervisory authority. Our lead authority is the Dutch Data Protection Authority (Autoriteit Persoonsgegevens), autoriteitpersoonsgegevens.nl. You may also contact the authority in your country of residence.

11Data security

This website is served over an encrypted connection (TLS/HTTPS). We take appropriate technical and organisational measures to protect personal data against loss, misuse and unauthorised access.

12Automated decisions and changes

We do not use automated decision-making or profiling. We may update this policy when our website or legal requirements change; the version published on this page applies.