Privacy Policy
(From 13.10.2025)
Part A
§ 1 General
We process your personal data (e.g., title, name, address, email address, telephone number) only in accordance with the provisions of German data protection law and the data protection law of the European Union (EU). The following provisions inform you about the processing purposes, legal bases, recipients, and retention periods, as well as your rights and the person responsible for your data processing. This privacy policy applies only to our websites. If you are redirected to other websites via links on our pages, please inform yourself there about how your data is handled.
(1) Definitions
Following the example of Art. 4 GDPR, this data protection notice is based on the following definitions:
– “Personal data” (Article 4 (1) GDPR) is any information relating to an identified or identifiable natural person (“data subject”). A person is identifiable if they can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, an online identifier, location data or with the help of information related to their physical, physiological, genetic, mental, economic, cultural or social identity characteristics. Identifiability may also be achieved by linking such information or other additional knowledge. The origin, form, or embodiment of the information is irrelevant (photos, video, or audio recordings may also contain personal data).
– “Processing” (Article 4 (2) GDPR) is any operation which is carried out on personal data, whether or not by automated (i.e., technology-based) means. This includes, in particular, the collection (i.e., acquisition), recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, comparison, linking, restriction, erasure or destruction of personal data, as well as the change of a purpose or objective on which the data processing was originally based.
– “Controller” (Article 4 No. 7 GDPR) is the natural or legal person, public authority, agency or other body which alone or jointly with others decides on the purposes and means of the processing of personal data.
– “Third party” (Article 4 No. 10 GDPR) means any natural or legal person, public authority, agency or body other than the data subject, the controller, the processor and the persons authorised to process the personal data under the direct responsibility of the controller or processor; this also includes other legal entities belonging to the group.
– „Processor“ (Article 4 No. 8 GDPR) is a natural or legal person, public authority, agency, or other body that processes personal data on behalf of the controller, in particular in accordance with the controller’s instructions (e.g., an IT service provider). In the context of data protection law, a processor is not a third party.
– “Consent” (Article 4 No. 11 GDPR) of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data concerning him or her.
§ 2 Contact
(1) Name and address of the controller
We are the responsible party for the processing of your personal data within the meaning of Art. 4 No. 7 GDPR:
Dominic Williams – Spotlesshost
Geeser Str. 37
54568, Gerolstein
Phone: 015143119008
info@spotlesshost.com
For further information about our company, please see the imprint on our website https://spotlesshost.com/impressum/ .
(2) Contact details of the data protection officer
Our company data protection officer is available to answer any questions you may have and is available to assist you with data protection issues at any time. His contact details are:
Dominic Williams – Spotlesshost
Geeser Str. 37
54568, Gerolstein
Phone: 015143119008
info@spotlesshost.com
(3) Purpose of processing
We process the personal data you provide to us via email, contact form, etc. to answer and process your inquiries. You are not obligated to provide us with your personal data. However, without your email address, we cannot respond to you by email.
(4) Legal basis for data processing
By law, any processing of personal data is in principle prohibited and is only permitted if the data processing falls under one of the following justifications:
– Article 6 (1) (a) GDPR (“consent”): If the data subject has voluntarily, in an informed manner and unambiguously indicated by a statement or other unambiguous confirmatory act that he or she agrees to the processing of personal data concerning him or her for one or more specific purposes;
– Article 6 (1) (b) GDPR: If the processing is necessary to fulfil a contract to which the data subject is party or to take steps at the request of the data subject prior to entering into a contract;
– Article 6 (1) (c) GDPR: If processing is necessary to fulfil a legal obligation to which the controller is subject (e.g. a statutory retention period);
– Article 6 (1) (d) GDPR: If processing is necessary to protect the vital interests of the data subject or of another natural person;
– Article 6 (1) (e) GDPR: If the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller or
– Article 6 (1) (f) GDPR (“Legitimate Interests”): If processing is necessary to protect the legitimate (in particular legal or economic) interests of the controller or a third party, unless the conflicting interests or rights of the data subject prevail (in particular if the data subject is a minor).
The storage of information in the end-user’s terminal equipment or access to information already stored in the terminal equipment is only permitted if it is covered by one of the following justifications:
– Section 25 (1) TDDDG: If the end user has given their consent based on clear and comprehensive information. Consent must be given in accordance with Article 6 (1) (a) GDPR;
– Section 25 (2) No. 1 TDDDG: If the sole purpose is to carry out the transmission of a message via a public telecommunications network or
– Section 25 (2) No. 2 TDDDG: If the storage or access is absolutely necessary so that the provider of a telemedia service can provide a telemedia service expressly requested by the user.
For each of the processing operations we carry out, we specify the applicable legal basis below. Processing may also be based on multiple legal bases.
(5) Legitimate interest
Our legitimate interest in processing data is to communicate with you quickly and respond to your inquiries cost-effectively. If you provide us with your address, we reserve the right to use it for direct mail marketing. You can protect your interest in data protection by discreetly sharing data (e.g., using a pseudonym).
(6) Categories of recipients
Hosting providers, shipping service providers for direct mail
(7) Data deletion and storage period
For each processing operation we perform, we specify below how long the data will be stored by us and when it will be deleted or blocked. Unless an explicit storage period is specified below, your personal data will be deleted or blocked as soon as the purpose or legal basis for storage no longer applies. Your data is generally stored only on our servers in Germany, subject to possible transfer in accordance with the provisions in (8) and (9).
However, storage may extend beyond the specified period in the event of an (impending) legal dispute with you or other legal proceedings, or if storage is required by legal regulations to which we as the controller are subject (e.g., Section 257 of the German Commercial Code (HGB), Section 147 of the German Fiscal Code (AO). If the storage period prescribed by law expires, the personal data will be blocked or deleted, unless further storage by us is necessary and there is a legal basis for doing so.
Your data will be deleted if the circumstances indicate that your inquiry or the matter in question has been conclusively clarified.
However, if a contract is concluded, we will retain the data required under commercial and tax law for the legally specified periods, i.e. normally ten years (cf. Section 257 HGB, Section 147 AO).
(8) Cooperation with processors
As with any larger company, we also use external domestic and foreign service providers to handle our business transactions (e.g., in the areas of IT, logistics, telecommunications, sales, and marketing). These providers operate solely on our instructions and are contractually obligated to comply with data protection regulations within the meaning of Art. 28 GDPR.
If your personal data is passed on by us to our subsidiaries or is passed on to us by our subsidiaries (e.g. for advertising purposes), this is done on the basis of existing order processing relationships.
(9) Conditions for the transfer of personal data to third countries
As part of our business relationships, your personal data may be transferred or disclosed to third parties. These companies may also be located outside the European Economic Area (EEA), i.e., in third countries. Such processing is carried out exclusively to fulfill contractual and business obligations and to maintain your business relationship with us (the legal basis is Art. 6 (1) (b) or (f) in conjunction with Art. 44 et seq. GDPR). We will inform you about the respective details of the transfer below at the relevant points.
The European Commission has certified that some third countries provide data protection comparable to the EEA standard through so-called adequacy decisions (a list of these countries and a copy of the adequacy decisions can be found here: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en). However, in other third countries to which personal data may be transferred, a consistently high level of data protection may not exist due to a lack of legal provisions. Where this is the case, we ensure that data protection is adequately guaranteed. This is possible through binding corporate rules, standard contractual clauses of the European Commission for the protection of personal data pursuant to Art. 46 (1) and (2) (c) GDPR (the 2021 standard contractual clauses are available at https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32021D0915&locale-en), certificates, or recognized codes of conduct. Please contact our data protection officer (see A.(3)) if you would like further information.
(10) No automated decision-making (including profiling)
We do not intend to use any personal data collected from you for any automated decision-making process (including profiling).
(11) No obligation to provide personal data
We do not make the conclusion of contracts with us dependent on your prior provision of personal data. As a customer, you are generally under no legal or contractual obligation to provide us with your personal data. However, we may be unable to provide certain services to a limited extent or at all if you do not provide the necessary data. Should this exceptionally be the case within the scope of the products we offer presented below, you will be informed separately.
(12) Legal obligation to transmit certain data
We may, under certain circumstances, be subject to a specific statutory or legal obligation to make the lawfully processed personal data available to third parties, in particular public authorities (Art. 6 (1) (c) GDPR).
(13) Your rights
You can assert your rights as a data subject regarding the processing of your personal data at any time using the contact details provided above. As a data subject, you have the right:
– to request information about your data processed by us in accordance with Art. 15 GDPR. In particular, you can request information about the purposes of processing, the category of data, the categories of recipients to whom your data has been or will be disclosed, the planned storage period, the existence of a right to rectification, erasure, restriction of processing or objection, the existence of a right to lodge a complaint, the origin of your data if it was not collected from us, as well as the existence of automated decision-making, including profiling, and, where applicable, meaningful information on its details;
– to request the immediate correction of inaccurate data or the completion of your data stored by us in accordance with Art. 16 GDPR;
– to request the deletion of your data stored by us in accordance with Art. 17 GDPR, unless the processing is necessary to exercise the right to freedom of expression and information, to fulfill a legal obligation, for reasons of public interest or to assert, exercise or defend legal claims;
– to request the restriction of the processing of your data in accordance with Art. 18 GDPR if you contest the accuracy of the data or if the processing is unlawful;
– in accordance with Art. 20 GDPR, to receive the data you have provided to us in a structured, common and machine-readable format or to request that it be transmitted to another controller (“data portability”);
– to object to processing pursuant to Art. 21 GDPR, provided that the processing is carried out on the basis of Art. 6 (1) S. 1 lit. e or lit. f GDPR. This is particularly the case if the processing is not necessary to fulfill a contract with you. Unless it is an objection to direct advertising, when exercising such an objection we ask you to explain the reasons why we should not process your data as we do. If your objection is justified, we will examine the situation and will either stop or adapt the data processing or show you our compelling legitimate reasons on the basis of which we continue the processing;
– pursuant to Art. 7 (3) GDPR, you have the right to revoke your consent (even before the GDPR came into force, i.e., before 25 May 2018) – that is, your voluntary, informed, and unambiguous consent, made clear by a statement or other unambiguous affirmative action, that you agree to the processing of your personal data for one or more specific purposes – at any time, if you have given such consent. This means that we may no longer continue the data processing based on this consent in the future, and
– in accordance with Art. 77 GDPR, to complain to a data protection supervisory authority about the processing of your personal data in our company, for example to the data protection supervisory authority responsible for us: State Data Protection Commissioner for Data Protection and Freedom of Information, Hintere Bleiche 34, 55116 Mainz, poststelle (at)datenschutz.rlp.de.
(14) Changes to the privacy policy
In line with the ongoing development of data protection law and technological or organizational changes, our privacy policy is regularly reviewed for any need for adjustment or addition. You will be notified of any changes, particularly on our German website at spotlesshost.com. This privacy policy is current as of October 2025.
Part B
§ 1 Visiting the website
(1) Explanation of the function
Information about our company and the services we offer can be found, in particular, at [address of the company’s website] and its associated subpages (hereinafter collectively referred to as „websites“). When you visit our websites, your personal data may be processed.
(2) Personal data processed
When you use our website for informational purposes, we collect, store and process the following categories of personal data:
„Log data“: When you visit our website, a so-called log data record (so-called server log files) is temporarily and anonymously stored on our web server. This consists of:
– the page from which the page was requested (so-called referrer URL)
– the name and URL of the requested page
– the date and time of the call
– a description of the type, language and version of the web browser used
– the IP address of the requesting computer, which is shortened so that a personal reference can no longer be established
– the amount of data transferred
– the operating system
– the message whether the call was successful (access status/Http status code)
– the GMT time zone difference
“Contact form data”: When using contact forms, the data transmitted through them will be processed (e.g. gender, first and last name, address, company, email address and the time of transmission).
In addition to the purely informational use of our website, we offer a subscription to our newsletter, which informs you about current developments in commercial law and events. When you subscribe to our newsletter, we collect, store, and process the following „newsletter data“:
– the page from which the page was requested (so-called referrer URL)
– the date and time of the call
– the description of the type of web browser used
– the IP address of the requesting computer, which is shortened so that a personal reference can no longer be established
– the email address
– the date and time of registration and confirmation
Please note that we evaluate your user behavior when sending the newsletter. For this evaluation, the emails sent contain so-called web beacons or tracking pixels, which are single-pixel image files stored on our website. For the evaluation, we link the aforementioned data and the web beacons to your email address and a unique ID. Links contained in the newsletter also contain this ID. The data is collected exclusively in pseudonymous form, meaning the IDs are not linked to your other personal data, and direct identification is excluded.
(3) Purpose and legal basis of data processing
We process the personal data described above in accordance with the provisions of the GDPR and other relevant data protection regulations, and only to the extent necessary. To the extent that the processing of personal data is based on Art. 6 (1) (f) GDPR, the aforementioned purposes also represent our legitimate interests.
The processing of log data serves statistical purposes and to improve the quality of our website, in particular the stability and security of the connection (the legal basis is Art. 6 (1) (a) or (f) GDPR).
Contact form data is processed to process customer inquiries (the legal basis is Art. 6 (1) (b) or (f) GDPR).
The newsletter data is processed for the purpose of sending the newsletter. By registering for our newsletter, you consent to the processing of your personal data (the legal basis is Art. 6 (1) (a) GDPR). We use the so-called double opt-in procedure to register for our newsletter. This means that after you register, we will send you an email to the email address you provided, asking you to confirm that you wish to receive the newsletter. The purpose of this procedure is to be able to verify your registration and, if necessary, to clarify any possible misuse of your personal data. You can revoke your consent to the sending of the newsletter and unsubscribe from the newsletter at any time. You can declare your revocation by clicking on the link provided in every newsletter email, by email to [company email address] or by sending a message to the contact details provided in the imprint.
If the processing of the data requires the storage of information in your terminal equipment or access to information that is already stored in the terminal equipment, Section 25 (1) and (2) TDDDG is the legal basis for this.
(4) Duration of data processing
Your data will only be processed for as long as necessary to achieve the aforementioned processing purposes; the legal bases specified in the context of the processing purposes apply accordingly. Regarding the use and storage period of cookies, please refer to the cookie banner.
Third parties employed by us will store your data on their systems for as long as is necessary in connection with the provision of the services for us in accordance with the respective order.
(5) Transfer of personal data to third parties; justification
The following categories of recipients, who are usually processors, may have access to your personal data:
– Service providers for the operation of our website and the processing of data stored or transmitted by the systems (e.g., for data center services, payment processing, IT security). The legal basis for the transfer is Art. 6 (1) (b) or (f) GDPR, unless they are contract processors;
– Government agencies/authorities, insofar as this is necessary to fulfill a legal obligation. The legal basis for the transfer is then Art. 6 (1) (c) GDPR;
– Persons employed to conduct our business operations (e.g., auditors, banks, insurance companies, legal advisors, regulatory authorities, parties involved in corporate acquisitions or the establishment of joint ventures). The legal basis for the transfer is Art. 6 (1) (b) or (f) GDPR.
For the guarantees of an adequate level of data protection when data are transferred to third countries, see A.(8).
Furthermore, we will only pass on your personal data to third parties if you have given your express consent to do so in accordance with Art. 6 (1) (a) GDPR.
§ 2 Web analysis with Google Analytics
(1) We use Google Analytics on this website. Google Analytics is a web analysis service. This service is provided by Google Ireland Limited („Google“), Gordon House, Barrow Street, Dublin 4, Ireland. Google Analytics uses cookies to recognize users and thus analyze usage behavior. These cookies are only set with consent. Consent can be revoked at any time and managed in our Cookie Consent Tool. The legal basis for the processing is Art. 6 (1) (a) GDPR and Section 25 (1) TDDDG. The information collected here is usually transferred to a Google server in the USA and stored there. When data is transferred to the USA, the Standard Contractual Clauses (SCC) of the EU Commission apply. The use of Google Analytics activates IP anonymization. The IP address of the respective user is shortened within the member states of the EU (or the European Economic Area) so that it can no longer be traced back to a natural person. In addition, Google commits to appropriate data protection through the Google Ads Data Processing Terms and Conditions and compiles an evaluation of website usage and website activity and provides the services associated with usage. The Google Ads Data Processing Terms apply to companies subject to the EU General Data Protection Regulation (GDPR) of the European Economic Area (EEA), the California Consumer Privacy Act (CCPA), or similar regulations. An additional browser plug-in can prevent the collected information (such as the IP address) from being sent to and used by Google. The plug-in and further information can be found at https://tools.google.com/dlpage/gaoptout?hl=de. Otherwise, the storage period depends on the type of data processed. Each customer can choose how long Google Analytics stores data before it is automatically deleted. Further information on Google’s data usage can also be found at https://support.google.com/analytics/answer/6004245?h|=de. For any further questions, please contact support-deutschland@google.com.
(2) Storage period
26 Months
(3) Right of withdrawal
You can revoke your consent at any time with future effect via our cookie banner or via our website.
You can also generally prevent cookies from being saved by setting your browser software accordingly; however, we would like to point out that in this case you may not be able to use all functions of this website to their full extent.
You can also prevent Google from collecting the data generated by the cookie and relating to your use of the website and from processing this data by Google by downloading and installing the browser plug-in available under the following link: optout
§ 3 Information about cookies
(1) We use cookies on our website. Cookies are small text files that are stored on your hard disk and associated with the browser you use, using a characteristic string of characters. These files allow certain information to be sent to the location that placed the cookies. Cookies cannot run programs or transmit viruses to your computer and therefore do not cause any damage. They are designed to make the internet more user-friendly and effective, and thus more pleasant for you.
Cookies can contain data that makes it possible to recognize the device used. However, cookies sometimes only contain information about certain settings that are not personally identifiable. Cookies cannot directly identify a user.
A distinction is made between session cookies, which are deleted as soon as you close your browser, and persistent cookies, which are stored beyond the individual session. In terms of their function, cookies are further divided into:
– Technical cookies: These are essential to navigate the website, use basic functions and ensure website security; they do not collect information about you for marketing purposes or store which websites you have visited;
– Performance cookies: These collect information about how you use our website, which pages you visit and, for example, whether errors occur during website usage; they do not collect any information that could identify you – all information collected is anonymous and is only used to improve our website and to find out what interests our users;
– Advertising cookies, targeting cookies: These are used to offer website users needs-based advertising on the website or offers from third parties and to measure the effectiveness of these offers; advertising and targeting cookies are stored for a maximum of 13 months;
– Sharing cookies: These are used to improve the interactivity of our website with other services (e.g., social networks); sharing cookies are stored for a maximum of 13 months.
The legal basis for cookies that are absolutely necessary to provide you with the service you have expressly requested is Section 25 (2) No. 2 TDDDG. Any use of cookies that is not absolutely necessary for this purpose constitutes data processing that is only permitted with your express and active consent in accordance with Section 25 (1) TDDDG in conjunction with Article 6 (1) (a) GDPR. This applies in particular to the use of performance, advertising, targeting or sharing cookies. Furthermore, we will only pass on your personal data processed by cookies to third parties if you have given your express consent to do so in accordance with Article 6 (1) (a) GDPR.
(2) Right of withdrawal
If you do not wish to receive these cookies, please deactivate them in your internet browser. However, this may limit the functionality of our website. You can also delete permanently stored cookies at any time via your browser.
(3) Social Media Plugins
We do not use social media plugins on our websites. If our websites contain symbols from social media providers (e.g., [name of social media providers with symbols on the company website]), we only use them for passive linking to the respective providers‘ websites.
(4) This privacy policy was created and is updated using the technology of janolaw GmbH.
(5) Page functionality
Hostaway
We use Hostaway to efficiently manage bookings. The integration enables centralized organization of booking information. We have concluded a data processing agreement with Hostaway. For more detailed privacy policy information, please visit: Privacy Policy – The Leading All-In-One Vacation Rental Management Software for Pros – Hostaway (https://hostaway.com/privacy-policy).