Privacy policy
Last updated: July 23, 2025
spottle GmbH, a limited liability company registered in Salzburg, Austria, under the commercial register number FN 527653 k (“spottle GmbH”), operates an online shop via the website www.myspottle.com (the “Website”). The following privacy policy applies to all customers placing orders via the spottle GmbH online shop (“Customers”).
1. General Information
This Privacy Policy explains the nature, scope, and purpose of the collection and use of personal data by spottle GmbH.
spottle GmbH will only use the information and data provided by the customer in accordance with Austrian and European data protection laws, this privacy policy, and with the customer’s consent.
2. Controller and Contact Information
The controller pursuant to Art. 4(7) GDPR is:
spottle GmbH
FN 527653 k
Halleiner Landesstraße 53 / 1
5061 Elsbethen
Austria
If you have questions about the collection, processing or use of your personal data, or wish to access, rectify, block, or delete your data, or revoke previously granted consent or object to a particular data usage, please contact us at support@spottle.net.
3. Data Collection and Purpose
3.1 Orders
When placing an order via our online shop, we collect personal data (such as name, address, email address, phone number, and billing/payment info). We also store your IP address, date, and time of order submission.
3.2 Newsletter
If you subscribe to our free newsletter, you consent to receiving regular promotional emails from us. We only require your email address for this.
At the time of subscription, we also collect your IP address and timestamp.
You will receive a confirmation email after signing up. Your subscription is not active until you confirm it by clicking the link in the email.
4. Legal Basis for Data Processing
4.1 Based on Your Consent
- Visiting our website
Your consent is the legal basis for storing the above-mentioned data when visiting the website of spottle GmbH. In addition to the data previously mentioned, cookies are stored on your device during your visit. Details regarding:
- Cookies can be found in section 7
- Social media plugins in section 8
- Google Analytics in section 10
We use your data as well as data from cookies and web tracking tools so you can make full use of all the features of our website and so we can tailor and optimize the website to your needs.
- Newsletter
Your consent is also the legal basis for processing your data for the purpose of sending you our newsletter.
You may withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal. A withdrawal of your consent also applies to any consents you may have granted before the GDPR came into effect on May 25, 2018.
Please note: Withdrawal only takes effect going forward.
You may revoke your consent at any time by simply sending an email to support@spottle.net. Alternatively, you can use the unsubscribe link included in every newsletter email we send you.
4.2. For the Fulfillment of Contractual or Pre-contractual Obligations
We process your data to fulfill contractual or pre-contractual obligations:
- Orders
The personal data related to orders placed via our website are used for the purpose of fulfilling the contract.
4.3. Based on a Legitimate Interest
- Email Advertising
If you have made a purchase in our online shop, we will use the email address provided in connection with your purchase to send you service-related information (such as satisfaction surveys) and marketing emails for our own similar offers.
Additionally, you may receive product recommendations based on your previous purchases in our online shop. These product recommendations are sent regardless of whether you have subscribed to our newsletter. The delivery of this advertising is based on our legitimate interest in staying in touch with our customers.
If you no longer wish to receive these emails, you can object by sending us a message in text form to the following email address: support@spottle.net. We will immediately stop sending advertising emails upon receipt of your objection.
- Resolution of Legal Disputes
We may also process personal data to assert, exercise or defend legal claims (e.g., in connection with rights and obligations under the GDPR).
4.4. Based on Legal Requirements
spottle GmbH processes personal data to comply with legal obligations under tax law as well as reporting and disclosure obligations to authorities:
- Compliance with Legal Requirements
Legal requirements may include, for example, retention obligations under tax and commercial law, or obligations to carry out monitoring measures to prevent economic crime or money laundering.
5. Data Transfer
The disclosure of personal customer data to third parties is excluded unless it is absolutely necessary for contract processing or legal obligations require such disclosure.
Within spottle GmbH, only those departments have access to your data that need it to fulfill their responsibilities within spottle GmbH, to protect legitimate interests, or to meet contractual and legal obligations.
In addition, we may transfer your personal data to the following parties for the following purposes:
- Public Authorities
spottle GmbH may transfer personal data to courts, supervisory authorities, tax authorities, and other public bodies in exceptional cases based on legal regulations (e.g., in cases of danger prevention or criminal prosecution).
- External Service Providers (so-called Data Processors)
spottle GmbH works with external service providers in the field of data processing (e.g., information technology (IT)) in order to benefit from their specific expertise. These so-called data processors act only under the instructions of spottle GmbH and are contractually obligated to comply with the applicable data protection regulations.
6. Transfer to Third Countries
A transfer of data to countries outside the EU or the EEA (so-called third countries) only takes place if it is necessary for the execution of your orders, legally required (e.g., tax reporting obligations), or you have given us your consent (e.g., for the use of social media plugins).
7. Cookies
When you first visit our website, a cookie banner will appear allowing you to consent to or reject non-essential cookies.
Cookies are small files that are stored on your device and save certain settings and data for exchange with our system via your browser. There are generally two types of cookies: so-called session cookies, which are deleted as soon as you close your browser, and temporary or permanent cookies, which are stored on your device for a longer period or indefinitely.
This storage helps us design our website and offerings in a user-friendly way and makes your use of the site easier – for example, by saving certain inputs so that you don’t have to re-enter them each time you visit.
8. Social Plugins
Our website uses social plugins (“Plugins”) from various social networks. These plugins allow you to, for example, share content or recommend products. On www.myspottle.net, the plugins are deactivated by default and therefore do not transmit any data.
If you activate these plugins, your browser establishes a direct connection to the servers of the respective social network as soon as you access a page of our website. The content of the plugin is transmitted directly to your browser by the social network and integrated into the webpage. Of course, you can deactivate the plugins again with a single click.
By integrating the plugins, the social network receives the information that you have accessed the corresponding page of our website. If you are logged into the social network, it can assign the visit to your account. If you interact with the plugins, for example by clicking the Facebook "Like" button or leaving a comment, the corresponding information is transmitted from your browser directly to the social network and stored there.
For details on the purpose and scope of the data collection and the further processing and use of the data by the social networks, as well as your rights and settings to protect your privacy, please refer to the data protection notices of the respective networks or websites. Links to these are provided further below.
If you do not want social networks to collect data about you via our website, you must log out of those networks before visiting our website.
Even if you are not logged into the social networks, websites with active social plugins can still send data to the networks. An active plugin sets a cookie with an identifier each time you visit the website. Since your browser automatically sends this cookie to the respective network server every time it connects, the network could theoretically create a profile of the websites visited by the user assigned to that identifier. And later – when logging into the social network – this identifier could potentially be linked to a specific person.
We use the following plugins on our website:
For www.spottle.net: Facebook, Google+, Twitter, Instagram, and Pinterest
The legal basis for the use of social plugins is your consent.
If you do not want social networks to collect data about you via active plugins, you can either deactivate the social plugins with a click on our website or set your browser to block “third-party cookies.” However, please note that with this setting, not only the plugins but also other cross-site features may no longer work properly.
9. Further Information on Individual Social Plugins
9.1. Facebook
We use plugins from the social network facebook.com, which is operated by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA ("Facebook"). You can find Facebook’s privacy policy here: Facebook Privacy Policy.
Facebook users should note that this website uses Facebook’s Website Custom Audiences communication tool. For this purpose, Facebook pixels are integrated into our website. These pixels mark you as a visitor to our site in an anonymized form — that is, without identifying you personally. If you later log in to Facebook, a non-reversible and thus non-personal checksum (profile) based on your usage data will be transmitted to Facebook for analysis and marketing purposes. For more information on the purpose and scope of data collection and the further processing and use of data by Facebook, as well as your options for protecting your privacy, please see Facebook’s data policies, which can be found at:
If you would like to opt out of Facebook Website Custom Audiences, you can do so at the above link.
9.2. Google+
We use plugins from the social network Google+, which is operated by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google").
An overview of Google’s plugins and how they look can be found here: https://developers.google.com/+/web/
9.3. Pinterest
We use plugins from the social network Pinterest, operated by Pinterest Inc., 635 High Street, Palo Alto, CA, USA ("Pinterest"). Pinterest’s privacy policy can be found here: Pinterest Privacy Policy
9.4. Instagram
We use plugins from the social network Instagram, operated by Instagram, LLC, 1601 Willow Road, Menlo Park, CA 94025, USA ("Instagram"). Instagram’s privacy policy can be found here: Instagram Privacy Policy
10. Google Analytics
This website uses Google Analytics, a web analysis service provided by Google Inc. ("Google"), if you have given your consent. Google Analytics uses so-called "cookies" — text files that are stored on your computer and enable analysis of your use of the website. The information generated by the cookie about your use of this website (including your IP address) is transmitted to a Google server in the USA and stored there. Google uses this information to evaluate your use of the website, compile reports on website activity for the website operator, and provide other services related to website and internet usage. Google may also transfer this information to third parties if required by law or if those third parties process the data on Google's behalf.
Google will never associate your IP address with any other data held by Google. You can prevent the installation of cookies either by not giving consent when visiting the website or by adjusting your browser settings. However, please note that if you choose to disable cookies, you may not be able to use all the functions of this website to their full extent. By using this website, you consent to the processing of data collected about you by Google in the manner and for the purposes described above. You may revoke your consent to the collection and storage of data at any time with future effect. Please also note that this website uses Google Analytics with the extension “_anonymizeIp()”, which means IP addresses are only processed in a shortened form to prevent direct personal identification.
The legal basis for the use of Google Analytics is your consent. If you have configured your browser settings to block third-party cookies or all cookies — even after giving consent — you may not be able to use this website or some of its features properly.
11. Data Security
The data transmitted to us by our customers is protected against external access in accordance with the latest technical standards, using our central system with firewalls and other security measures.
Data transferred between the user and spottle GmbH is always encrypted using SSL/TLS encryption whenever you use an input form on the website.
12. Retention Period
spottle GmbH processes and stores your personal data only as long as necessary to achieve the purpose for which it was collected. Once the data is no longer needed for that purpose, it will be deleted — unless a temporary extended processing is necessary for the following reasons:
- Statutory retention periods
To comply with commercial and tax law obligations under the Austrian Federal Fiscal Code (BAO) and the Austrian Commercial Code (UGB).
- Preservation of evidence
To retain evidence within the scope of statutory limitation periods.
According to the Austrian General Civil Code (ABGB), such limitation periods may be up to thirty years, with the standard limitation period being three years.
In addition, the following applies to specific cases:
- Visiting the website
Your data is generally deleted as soon as the respective session ends. Log files are deleted after seven days. Extended storage may be possible in exceptional cases. In this case, the users’ IP addresses are deleted or anonymized to prevent any personal reference.
- Newsletter
If you register for our newsletter on www.myspottle.com, we use the double opt-in procedure. This means you will receive an email after registration asking you to confirm your subscription. If you do not confirm within 24 hours, your data will be blocked and automatically deleted after one month.
We base our newsletter delivery on your consent, valid until the end of the third calendar year following your consent. After this period, unless renewed, your data will be deleted.
Any personal data collected during the submission process (e.g. IP address) will be deleted no later than seven days after submission.
13. Data Protection Rights
As a data subject, you are entitled to the following rights under the General Data Protection Regulation (GDPR):
- Right of access:
Under Art. 15 GDPR, you may request information from us about whether spottle GmbH processes personal data concerning you, and what data that entails.
- Right to rectification:
If your information is incorrect, you may request correction under Art. 16 GDPR. If your data is incomplete, you can request completion.
If spottle GmbH has shared your data with third parties, those parties will be informed of the correction — if legally required.
- Right to erasure of personal data:
You have the right to have your data erased by spottle GmbH, provided the conditions of Art. 17 GDPR are met (especially when the original purpose for processing the data no longer applies).
- Right to restriction of processing:
You have the right to restrict the processing of your data, provided the conditions of Art. 18 GDPR are fulfilled.
- Right to data portability:
Additionally, upon request, we will provide your data for further use or transfer it to a third party designated by you.
- Right to withdraw consent (see details above in section 4.1):
If you have given consent for the processing of personal data, you may withdraw that consent at any time with future effect. This withdrawal does not affect the lawfulness of processing carried out based on consent before its withdrawal.
After withdrawal, spottle GmbH may only continue to process your personal data if legally required to do so.
- Right to object to processing:
According to Art. 21(1) GDPR, you have the right to object at any time to the processing of your personal data that is based on Art. 6(1)(f) GDPR (processing based on legitimate interests).
If you object, we will stop processing your personal data for the relevant purposes unless:
- We can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms, or
- The processing is necessary for the establishment, exercise, or defense of legal claims.
If your objection specifically concerns or includes direct marketing, we will no longer process your data for that purpose.
You may object informally, for example, via email to: support@spottle.net
- Right to lodge a complaint:
Additionally, you have the right to file a complaint with the data protection authority in accordance with Art. 77 GDPR.
14. No Automated Decision-Making
To establish and manage the contractual relationship, spottle does not use fully automated decision-making processes within the meaning of Article 22 GDPR.
15. Payment Method: Klarna
In cooperation with Klarna AB (publ), Sveavägen 46, S-11134 Stockholm, we offer the following payment options. Payments are made directly to Klarna:
- Invoice: The payment period is 14 days from the date of dispatch of the goods. The full terms and conditions for invoice purchases for deliveries to Germany can be found [here], and for deliveries to Austria [here].
- Sofort (Immediate Transfer): Your account will be charged immediately after placing the order.
- Direct Debit: Your account will be debited after the goods have been shipped. You will be informed of the date by email.
Use of the invoice and direct debit payment options requires a positive credit check. Therefore, as part of initiating and processing the purchase, we forward your data to Klarna for address and creditworthiness verification. Please understand that we can only offer those payment methods that are permitted based on the results of the credit check. Further information and Klarna's terms of use can be found for Germany [here], and for Austria [here]. General information about Klarna is available [here]. Your personal data will be processed in accordance with the applicable data protection regulations and as described in Klarna’s privacy notices for Germany / Austria.