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Privacy Policy

Status: 2 November 2025

Scope: This privacy policy applies to the website https://sphereoptics.de (including contact forms, download and enquiry forms), to our newsletter distribution and, as described below, to embedded third-party content (e.g. YouTube) and reach/usage analysis (e.g. Google Analytics, Microsoft Clarity). Product and customer portals are not included; separate data protection notices may apply in this case.

1. Controller and Data Protection Officer

Controller (Art. 4 No. 7 GDPR):

SphereOptics GmbH, Gewerbestraße 13, 82211 Herrsching, Germany

Tel.: +49 8152 983 78-90, Email: info@sphereoptics.de

Website: https://www.sphereoptics.de

Management: Ian Stansfield, Robert Yeo

Affiliation: SphereOptics GmbH is part of the Pro-Lite group of companies (majority shareholder: Pro-Lite Technology Ltd). This privacy policy refers to the processing activities of SphereOptics GmbH for the German website and the services described therein.

Data protection supervisor:

Mr. Mario Rath, Fischerei 39, 86911 Dießen am Ammersee, Germany

Tel: +49 160 8457235, E-Mail: datenschutz@mario-rath.de

Competent supervisory authority:

Bavarian State Office for Data Protection Supervision (BayLDA), Promenade 18, 91522 Ansbach, Germany, https://www.lda.bayern.de

2. General information on data processing

We process personal data in accordance with the GDPR (General Data Protection Regulation), the BDSG (Federal Data Protection Act) and the TTDSG (Telecommunications-Telemedia-Data Protection Act). The details of the data processed depend on the use of our website and services.

Categories of data subjects: website visitors, communication partners, newsletter subscribers, applicants.

Categories of data: Master data (e.g. name, contact data), communication data (e.g. e-mail, IP address), content data (free text), usage/meta data (e.g. access times, device information), application data.

Sources of data: In principle, we collect data directly from you. In individual cases, we receive data from other sources (e.g. public registers) – details are provided in the relevant section.

Legal basis (excerpt): Art. 6 para. 1 lit. a GDPR (consent), lit. b (contract/initiation), lit. c (legal obligation), lit. f (legitimate interests). For applications: § 26 BDSG.

3. Hosting, server log files, security

Purposes: Provision of the website, stability, security, error analysis.

Data processed: IP address, date/time, requested resource/URL, referrer, user agent, status and transmission data if applicable.

Legal basis: Art. 6 para. 1 lit. f GDPR (legitimate interest in safe and functional operation).

Storage period: Server logs are stored for a maximum of 7 days and then deleted or anonymized.

Recipients (Group & Processors):

  • Techy Business Services (United Kingdom): Technical operation/hosting of the website and agency services on behalf of SphereOptics GmbH (Art. 28 GDPR). Transfers to the UK are made on the basis of the EU Commission’s adequacy decision for the UK.
  • Other IT service providers (e.g. e-mail/CDN), each with an AV contract (Art. 28 GDPR).

Security: We use TLS encryption, access controls, backups and monitoring, among other things (Art. 32 GDPR).

4. Cookies & Similar Technologies (TTDSG) and Consent Management

Principle: The storage of information on your device or the reading of information stored there (e.g. cookies, local storage, pixels) is only permissible with your consent (§ 25 para. 1 TTDSG) unless technically necessary. Technically required technologies are also permissible without consent according to Section 25 (2) TTDSG.

We use a consent management tool (CMP). You can view and revoke your choice at any time in the footer under “Cookie settings”. The CMP logs consents (timing, categories) and blocks unnecessary scripts until consent.

Scripts that are not required – in particular Google Analytics 4 and Microsoft Clarity – are only loaded after consent has been given.

Categories:

  1. Necessary (e.g. session/security/consent cookies; Purpose: Operation, Security, Consent Management).
  2. Statistics (e.g. Google Analytics 4; Purpose: Range measurement).
  3. Marketing/convenience (e.g., YouTube/LinkedIn embeds; Purpose: embedding and personalization, possibly tracking by third parties).

Legal bases:

  • Required technologies: Art. 6 para. 1 lit. f GDPR in conjunction with § 25 para. 2 TTDSG.
  • Statistics/Marketing/Convenience: Art. 6 para. 1 lit. a GDPR in conjunction with § 25 para. 1 TTDSG (consent).

Storage period & specific cookies: The current terms and providers can be found in the cookie overview in the CMP.

5. Contact (e-mail/forms/phone)

Purposes: Processing of inquiries, communication, preparation of offers.

Data: Name, contact details, content of the request, metadata (time stamp), if applicable, company affiliation.

Legal basis: Art. 6 para. 1 lit. b GDPR (pre-contractual communication/contract) or lit. f (legitimate interest in efficient communication).

Storage period: We regularly delete inquiries after 12 months, unless there are any legal retention obligations.

Recipients: Hosting/email providers as processors.

6. Newsletter (CleverReach)

Purposes: To send you information about products, services and events.

Data: Email address, name if applicable, opt-in/opt-out times, interaction data (opens/clicks, if allowed).

Service provider: CleverReach GmbH & Co. KG, Schafjückenweg 2, 26180 Rastede, Germany (processor, Art. 28 GDPR).

Legal bases:

  • Consent (double opt-in), Art. 6 (1) (a) GDPR.
  • Existing customer acquisition: Art. 6 para. 1 lit. f GDPR in conjunction with § 7 para. 3 UWG (only for own similar products/services, with objection at any time).

Tracking in e-mails: Only if you have consented in the CMP or when registering.

Revocation/objection: At any time via the unsubscribe link or by e-mail to us.

Storage period: After unsubscribing, we store the e-mail exclusively in a blacklist to prevent further mailings (legitimate interest, Art. 6 para. 1 lit. f GDPR).

7. Web Analytics – Google Analytics 4

Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

Purpose: Reach measurement, improvement of content and usability.

Function: GA4 sets cookies/similar technologies; we use IP anonymization. Data may be transferred to the United States. Transfers are based on Google’s EU-US Data Privacy Framework (DPF) or Standard Contractual Clauses (SCC).

Legal basis: Consent (Art. 6 para. 1 lit. a GDPR; § 25 para. 1 TTDSG).

Objection/revocation: at any time via the CMP (“Cookie Settings”).

Storage period of events: usually 2–14 months (depending on configuration).

Order processing: concluded with Google (Art. 28 GDPR).

8. Usage Analysis – Microsoft Clarity

Anbieter: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Irland.

Purpose: Understanding of click and scroll behavior, heat maps, technical error analysis; Improving the user experience.

Data: usage data (mouse movements, clicks, scroll depth, technical device information), abbreviated IP address; Recordings are pseudonymised. Free text and form fields are escaped by default by our configuration.

Profiling note: Clarity can allow an evaluation of user behavior in combination with other data (Art. 4 No. 4 GDPR). No automated decisions within the meaning of Art. 22 GDPR.

Third country transfers: Possible transfer to third countries (including the United States) via Microsoft infrastructure. Secured via EU-US Data Privacy Framework (DPF) and/or Standard Contractual Clauses (SCC).

Legal basis: Consent (Art. 6 para. 1 lit. a GDPR; § 25 para. 1 TTDSG).

Revocation: at any time via the CMP.

Order processing: concluded with Microsoft (Art. 28 GDPR).

9. Integration of third-party content (YouTube, LinkedIn)

We use YouTube and LinkedIn. Third-party content is only loaded after your consent (2-click solution via the CMP). When loading, the provider can set its own cookies/trackers and process data (including IP address, device information, referrer); transfers to third countries (USA) are possible.

YouTube (Google Ireland Limited): Integration in the extended data protection mode.

LinkedIn (LinkedIn Ireland Unlimited Company): Social plugins/embeds only after consent.

Legal basis: Art. 6 para. 1 lit. a GDPR; § 25 para. 1 TTDSG.

Revocation: at any time via the CMP.

10. Applications

Purpose: To carry out the selection procedure, to establish an employment relationship.

Data: Master data, contact details, qualification data, correspondence.

Legal basis: § 26 para. 1 BDSG (initiation of employment relationship); if applicable, Art. 6 (1) (b) GDPR.

Special categories: Only if required by law or with explicit consent (Art. 9 para. 2 GDPR).

Storage period:

  • In case of cancellation: 6 months after completion of the procedure.
  • Talent pool: Only with consent (usually 12 months).

Recipient: HR service provider / hosting as a processor.

11. Recipients, order processing, transfers to third countries

We transmit data to service providers (e.g. hosting, e-mail, newsletter, analysis) only on the basis of a data processing agreement (Art. 28 GDPR).

transfers to third countries (esp. USA, UK) only take place if

  • an adequacy decision exists (e.g. United Kingdom; EU–US Data Privacy Framework), or
  • Standard Contractual Clauses (SCCs) and, if necessary, additional measures, or
  • consent (Art. 49 para. 1 lit. a GDPR).

Intra-group transfers:

SphereOptics GmbH is part of the Pro-Lite Group. For corporate administrative purposes (e.g. IT operations, uniform reporting, group-wide security measures), personal data may be transmitted to Pro-Lite Technology Ltd. and processed there as an independent controller. The legal basis for this is Art. 6 (1) (f) GDPR (legitimate interest in efficient group administration and IT security). Group agreements exist on data protection, confidentiality and security; Transfers to the United Kingdom are based on the EU Commission’s adequacy decision. Your rights will be protected.

Concrete:

  • Pro-Lite Technology Ltd. (UK): if applicable, own responsibility for administrative group processes (Art. 6 para. 1 lit. f GDPR).
  • Google Ireland/Microsoft Ireland (Analytics/Clarity): if necessary, transfers to the USA under the DPF or via SCC (see chapter 7/8).
12. Storage period

Unless otherwise stated in this declaration, we delete personal data if it is no longer required for the respective purposes and does not conflict with any statutory retention obligations (e.g. HGB/AO up to 10 years). For log data, see Section 3, for applications, Section 10, for newsletters, Section 6.

13. Rights of data subjects (Art. 15–22 GDPR) and complaint

You have the right to information, correction, deletion, restriction, data portability and objection to processing based on Art. 6 (1) (e) or (f) GDPR. In the case of processing based on your consent, you can revoke it at any time with effect for the future.

You also have the right to lodge a complaint with a data protection supervisory authority (the BayLDA is usually responsible, see above).

Contact for exercise of rights: datenschutz@mario-rath.de

14. Information on the right to object in accordance with Art. 21 GDPR

You have the right to object at any time to processing based on Art. 6 (1) (e) or (f) GDPR on grounds relating to your particular situation. This also applies to profiling based on it. We will then no longer process the personal data unless we can prove compelling reasons worthy of protection.

Where we process personal data for direct marketing, you have the right to object at any time to processing for the purpose of such marketing; this also applies to profiling, insofar as it is related to direct advertising.

15. No automated decisions in individual cases (Art. 22 GDPR)

We do not make decisions based solely on automated processing that produce legal effects concerning you or similarly significantly affect you. Usage data (e.g. in Clarity/Analytics) is not evaluated in order to make decisions with legal effect.

16. Obligation to provide data

There is no legal or contractual obligation to provide personal data. Data is required for certain functions (e.g. contact, newsletter); without it, the use of the function is not possible.

17. Changes to this Privacy Policy

We will adapt this statement if the law, services or processes change. The current version is available at https://sphereoptics.de/datenschutz. Changes are marked by the status date.

18. Cookie overview (excerpt)

The complete, always up-to-date list (name, provider, purpose, duration) can be found in the CMP under “Cookie settings”.

Required

  • ccm_consent (CMP): Stores consent status; Term usually 6–12 months.
  • PHPSESSID/Session-ID: Session control; Duration: until the end of the session.

Statistics (only with consent)

  • *_ga, *_ga_* (Google Analytics 4): Reach measurement; Storage periods depend on configuration (typically 2–14 months).

Marketing/Convenience (only with consent)

  • YouTube Local Storage/Player Cookies: Playback Preferences; Duration: variable.
  • LinkedIn Cookies/Pixels: Embedding/Interactions; Duration: variable.