Privacy

We are very pleased about your interest in our company. Data protection has an exceptionally high priority for the management of Insa Hoffmann. Using the websites of Insa Hoffmann is generally possible without providing any personal data. However, if a data subject wishes to use special services of our company via our website, the processing of personal data may become necessary. If the processing of personal data is required and there is no legal basis for such processing, we generally obtain the consent of the data subject. The processing of personal data, such as the name, address, e-mail address, or telephone number of a data subject, is always carried out in accordance with the General Data Protection Regulation (GDPR) and in compliance with the country-specific data protection regulations applicable to Insa Hoffmann. With this privacy policy, our company aims to inform the public about the type, scope, and purpose of the personal data we collect, use, and process. Furthermore, data subjects are informed through this privacy policy about their rights. Insa Hoffmann, as the controller responsible for processing, has implemented numerous technical and organizational measures to ensure as complete protection as possible of the personal data processed via this website. Nevertheless, internet-based data transmissions can generally exhibit security vulnerabilities, so absolute protection cannot be guaranteed. For this reason, it is up to each data subject to transmit personal data to us by alternative means, such as by telephone.

1. Definitions

The privacy policy of Insa Hoffmann is based on the terms used by the European legislator when enacting the General Data Protection Regulation (GDPR). Our privacy policy is intended to be easily readable and understandable both for the public and for our customers and business partners. To ensure this, we would like to first explain the terminology used. We use the following terms in this privacy policy:

• a) Personal data

  Personal data means any information relating to an identified or identifiable natural person (hereinafter “data subject”). An identifiable natural person is one who can be identified, directly or indirectly, particularly by reference to an identifier such as a name, identification number, location data, online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

• b) Data subject

  A data subject is any identified or identifiable natural person whose personal data is processed by the controller.

• c) Processing

  Processing means any operation or set of operations performed on personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or otherwise making available, alignment or combination, restriction, erasure, or destruction.

• d) Restriction of processing

  Restriction of processing means the marking of stored personal data with the aim of limiting their future processing.

• e) Profiling

  Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that person’s work performance, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements.

• f) Pseudonymization

  Pseudonymization means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

• g) Controller or responsible party

  Controller or responsible party means the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of processing of personal data. Where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

• h) Processor

  Processor means a natural or legal person, public authority, agency, or other body which processes personal data on behalf of the controller.

• i) Recipient

  Recipient means a natural or legal person, public authority, agency, or another body to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the context of a particular inquiry under Union or Member State law are not considered recipients.

• j) Third party

  Third party means a natural or legal person, public authority, agency, or body other than the data subject, the controller, the processor, and persons who, under the direct authority of the controller or processor, are authorized to process personal data.

• k) Consent

  Consent 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 relating to him or her.

2. Name and address of the controller

Controller within the meaning of the General Data Protection Regulation (GDPR), other data protection laws applicable in the Member States of the European Union, and other provisions with a data protection character is: Insa Hoffmann Rebmättleweg 4 79400 Kandern Germany Tel.: +49 7626 9729624 E-Mail: art@insahoffmann.com Website: www.insahoffmann.com

3. Cookies

The websites of Insa Hoffmann use cookies. Cookies are text files that are stored on a computer system via an internet browser. Many websites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a string of characters through which websites and servers can be assigned to the specific internet browser in which the cookie is stored. This allows the visited websites and servers to distinguish the individual browser of the data subject from other internet browsers containing other cookies. A particular internet browser can thus be recognized and identified via the unique cookie ID. By using cookies, Insa Hoffmann can provide users of this website with more user-friendly services that would not be possible without setting cookies. Cookies allow us to optimize the information and offers on our website for the user. Cookies enable us to recognize the users of our website. The purpose of this recognition is to make it easier for users to use our website. For example, the user does not have to enter login data every time they visit the website because it is taken over by the website and the cookie stored on the user’s computer system. Another example is a shopping cart cookie in an online shop. The online shop remembers the items a customer has placed in the virtual shopping cart through a cookie. The data subject can prevent the setting of cookies via our website at any time by adjusting the internet browser used and thereby permanently object to the setting of cookies. Furthermore, already set cookies can be deleted at any time via an internet browser or other software programs. This is possible in all common internet browsers. If the data subject disables the setting of cookies in the internet browser used, it may be that not all functions of our website can be fully used.

4. Collection of general data and information

The website of Insa Hoffmann collects a range of general data and information each time a data subject or an automated system accesses the website. These general data and information are stored in the server’s log files. Collected data may include the (1) types and versions of browsers used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reached our website (so-called referrer), (4) the sub-websites accessed via an accessing system, (5) the date and time of access to the website, (6) an Internet Protocol (IP) address, (7) the Internet service provider of the accessing system, and (8) other similar data and information used for the prevention of risks in case of attacks on our IT systems. When using this general data and information, Insa Hoffmann does not draw any conclusions about the data subject. This information is rather needed to (1) correctly deliver the content of our website, (2) optimize the content of our website as well as the advertising for it, (3) ensure the permanent functionality of our IT systems and the technology of our website, and (4) provide law enforcement authorities with the necessary information in the event of a cyberattack. These anonymously collected data and information are statistically evaluated by Insa Hoffmann and also with the aim of increasing data protection and data security in our company to ultimately ensure an optimal level of protection for the personal data we process. The anonymous data from the server log files are stored separately from all personal data provided by a data subject.

5. Registration on our website

Data subjects have the possibility to register on the website of the controller by providing personal data. The personal data transmitted to the controller is determined by the respective input mask used for registration. The personal data entered by the data subject is collected and stored exclusively for internal use by the controller and for its own purposes. The controller may arrange for the data to be transmitted to one or more processors, such as a shipping service, who will also use the personal data exclusively for internal purposes attributable to the controller. Through registration on the website, the IP address assigned by the data subject’s Internet Service Provider (ISP), the date, and time of registration are also stored. These data are stored to prevent misuse of our services and to allow tracing in case of criminal offenses. The transfer of these data to third parties does not generally occur unless there is a legal obligation or the transfer serves law enforcement. Registration with voluntary provision of personal data allows the controller to offer the data subject content or services that can only be offered to registered users. Registered persons may modify or delete their personal data at any time. The controller will provide information upon request about what personal data are stored. Furthermore, the controller will correct or delete personal data upon request or instruction of the data subject, unless legal retention obligations prevent this. All employees of the controller are available as contact persons in this context.

6. Subscription to our newsletter

Users have the option to subscribe to the company’s newsletter. The personal data transmitted during subscription is determined by the respective input mask used. The newsletter can only be received if (1) the data subject has a valid email address and (2) registers for the newsletter. A confirmation email is sent via double opt-in for legal reasons. This verifies whether the owner of the email address has authorized receiving the newsletter. The ISP-assigned IP address of the data subject’s computer system at the time of subscription, as well as the date and time, are stored for legal protection against misuse. Personal data collected during newsletter registration is used exclusively for sending the newsletter and, if necessary, informing subscribers about service changes. There is no transfer of data to third parties. Subscriptions can be canceled at any time, and consent for data storage can be revoked via a link in each newsletter or directly on the website.

7. Newsletter tracking

The newsletters contain tracking pixels, miniature graphics embedded in HTML emails, to enable log file recording and analysis. This allows statistical evaluation of marketing campaign success. The controller can see if and when an email was opened and which links were clicked. The data are not shared with third parties. Consent can be revoked at any time, after which the data are deleted. Unsubscribing automatically counts as revocation.

8. Contact via the website

The website provides information for fast electronic contact and direct communication, including a general email address. Data submitted via email or contact form are automatically stored and used only to respond to inquiries. No transfer to third parties occurs.

9. Routine deletion and blocking of personal data

The controller processes and stores personal data only for the period necessary to achieve the storage purpose or as required by law. Once the storage purpose ceases or retention periods expire, data are routinely blocked or deleted in accordance with legal requirements.

10. Rights of the data subject

• a) Right to confirmation

  Data subjects have the right to obtain confirmation from the controller as to whether personal data concerning them are being processed. This can be requested at any time.

• b) Right to access

  Data subjects have the right to obtain free information about stored personal data and a copy, including purposes, categories, recipients, duration, correction or deletion rights, complaints, and sources if data were not collected from the subject. This also applies to data transfers to third countries or international organizations. Requests can be made at any time.

• c) Right to rectification

  Data subjects can request immediate correction of inaccurate personal data and completion of incomplete data. Requests can be made at any time.

• d) Right to erasure (“right to be forgotten”)

  Data subjects can request deletion of personal data if one of several conditions applies (no longer necessary, consent withdrawn, objection, unlawful processing, legal obligations, etc.). The controller will take all necessary measures, including technical, to inform others processing such data if required. Requests can be made at any time.

• e) Right to restriction of processing

  Data subjects may request restriction of processing if accuracy is disputed, processing is unlawful, data is no longer needed by the controller but required by the subject, or objection rights apply. Requests can be made at any time.

• f) Right to data portability

  Data subjects may receive their personal data in a structured, commonly used, machine-readable format and transfer it to another controller if processing is based on consent or contract and is automated. Requests can be made at any time.

• g) Right to object

  Data subjects may object at any time to processing for public tasks, legitimate interests, or direct marketing, including profiling, based on their specific situation. The controller must then cease processing unless overriding legitimate grounds exist. Requests can be made at any time.

• h) Automated decisions including profiling

  Data subjects have the right not to be subject to decisions based solely on automated processing, including profiling, with legal effects or significant impact unless necessary for contract, authorized by law, or consented. The controller ensures rights protection including human intervention and contestation. Requests can be made at any time.

• i) Right to withdraw consent

  Data subjects may withdraw consent to personal data processing at any time. Requests can be made at any time.

11. Legal basis for processing

Processing based on consent uses Art. 6 I lit. a GDPR. Processing necessary for contracts uses Art. 6 I lit. b GDPR. Legal obligations rely on Art. 6 I lit. c GDPR. Vital interests rely on Art. 6 I lit. d GDPR. Legitimate interests not covered by other bases use Art. 6 I lit. f GDPR. Legitimate interest can include customer relationships (Recital 47, GDPR).

12. Legitimate interests pursued by the controller or a third party

If processing is based on Art. 6 I lit. f GDPR, our legitimate interest is conducting business for the benefit of all employees and shareholders.

13. Duration for which personal data are stored

Data are stored according to statutory retention periods. After expiration, data are routinely deleted if no longer needed for contract fulfillment or initiation.

14. Legal or contractual requirement to provide personal data; necessity for contract; consequences of non-provision

Providing personal data may be legally or contractually required. For example, a contract may require submission of personal data. Failure to provide data may prevent contract conclusion. Data subjects are informed by our employees before providing data.

15. Existence of automated decision-making

As a responsible company, we do not engage in automated decision-making or profiling. Developed by the SaaS LegalTech specialists of Willing & Able, creators of the Online GDPR Training. The privacy policy texts were prepared and published by Prof. Dr. h.c. Heiko Jonny Maniero and attorney Christian Solmecke.