Privacy Policy for 360SPRO (Main Domain and Subdomain)
Effective: April 6, 2025
This Privacy Policy applies to the use of our websites https://360spro.de and https://support.360spro.de. It is directed at users located in the European Economic Area (EEA), Switzerland, and the United Kingdom.
- Controller
360SPRO
Haldesdorfer Straße 14
22179 Hamburg – Germany
Email: [email protected]
Phone: +49 40 602 986 16
- General Information on Data Processing
We process personal data for the following purposes:
- Operation and provision of websites and services
- Contact and communication
- Newsletter delivery
- Contract processing on the support platform
- User account management
- Payment processing
- Use of AI-based support features
- Security, stability, and abuse prevention
- Data Processing on https://360spro.de (Main Domain)
Purposes, data types and legal bases:
Purpose | Data types | Legal basis |
Website visit | IP address, browser type, timestamp, operating system | Art. 6(1)(f) GDPR |
Contact form | Name, email, message | Art. 6(1)(b) GDPR |
Newsletter | Email address | Art. 6(1)(a) GDPR |
Security/CDN | IP address, access data | Art. 6(1)(f) GDPR |
Services used:
- Hosting: Hetzner Online GmbH, Germany
- CDN: Cloudflare Germany GmbH (data processing with SCCs)
- Newsletter: Mailchimp (The Rocket Science Group LLC, USA – DPA and SCCs according to Art. 28, 46 GDPR)
- Embedded content: YouTube, Google Fonts (only after consent)
- Data Processing on https://support.360spro.de (Subdomain)
Data types processed:
- Basic data: Name, email address, username
- Login data: via Clerk (USA)
- Payment data: transaction ID, method, timestamp (Stripe)
- Support data: chat history, ticket contents, SAP requests
- Technical data: IP address, device, browser, timestamp
- AI data: user input and generated responses
Purposes and legal bases:
Purpose | Legal basis |
User account/login | Art. 6(1)(b) GDPR |
Payment processing | Art. 6(1)(b) GDPR |
Use of SAP AI | Art. 6(1)(a) GDPR |
Security & abuse prevention | Art. 6(1)(f) GDPR |
Analytics & optimization | Art. 6(1)(f) GDPR |
AI Technologies: The SAP AI is based on an internal 360SPRO model. Third-party services like OpenAI or Azure OpenAI may be used with user consent. No advertising-based analysis of content occurs.
Technical infrastructure provided by:
- Vercel Inc. (USA) – platform hosting (SCCs in place)
- Clerk Inc. (USA) – authentication (SCCs)
- Stripe Payments – payment processing (SCCs, DPA)
- OpenAI / Azure – AI integration (SCCs, consent-based)
- Offshore partner India – technical implementation (DPA, SCCs)
- Cookies and Consent Management
We use cookies for:
- Technically necessary purposes (Art. 6(1)(f) GDPR)
- Optional purposes (analytics, media – only with consent under Art. 6(1)(a) GDPR)
You can change your cookie settings at any time via the “Cookie Settings” link in the footer. Consents are logged.
- Data Retention
Personal data is only stored as long as necessary for the purposes described or as required by law.
- Your Rights
You have the following rights under the GDPR:
- Access (Art. 15 GDPR)
- Rectification (Art. 16 GDPR)
- Erasure (Art. 17 GDPR)
- Restriction of processing (Art. 18 GDPR)
- Data portability (Art. 20 GDPR)
- Objection to processing (Art. 21 GDPR)
- Withdrawal of consent (Art. 7(3) GDPR)
Please send inquiries to: [email protected]
- International Data Transfers
Data transfers to third countries (e.g., USA, India) occur only:
- on the basis of EU Standard Contractual Clauses (SCCs), or
- where an adequacy decision by the European Commission exists
- Supervisory Authority & Right to Lodge a Complaint
Responsible authority for 360SPRO: Hamburg Commissioner for Data Protection and Freedom of Information (HmbBfDI)
Website: https://datenschutz-hamburg.de
- Changes to This Privacy Policy
We reserve the right to amend this Privacy Policy to reflect technical or legal developments. The current version is always available on our websites.