Data privacy

1. General information on the collection of personal data

The protection of your personal data is particularly important to instrAction GmbH ("instrAction"). This privacy policy describes how instrAction ("we", "us" and "our") uses and protects personal data collected via https://www.instraction.com. Personal data is any data that is personally identifiable to you, such as your title, name, address, email address, IP address, etc. Your personal data will only be collected and processed by us in accordance with the provisions of the EU General Data Protection Regulation ("GDPR") and other provisions of European and applicable national data protection law. The collection and use of personal data only takes place after you have consented to this or the processing of the data is permitted by legal regulations. The following provisions inform you in each case about the type, scope and purpose of the collection and processing of your personal data. In the event that we use commissioned service providers for individual functions of our offer or our services or use your data for advertising or analysis purposes, we will also inform you in detail about the respective processes below. At this point, we will also inform you about the defined criteria and the storage period. We also inform you about your rights regarding any data processing. This data protection declaration refers exclusively to our website. In the event that you are forwarded to third-party websites via links from our website, please inform yourself there about the respective handling of your data.

2. Contact information of the person responsible

The data protection controller within the meaning of the GDPR and all other applicable EU data protection regulations ("Controller") is instrAction. If you have any questions, suggestions or criticism regarding the data protection of our website, please contact: instrAction GmbH, Carl-Friedrich-Gauß-Ring 5, 69124 Heidelberg, Germany, Phone: +49 6221-650 99 46, E-Mail: info@instraction.de

3. Explanation of the legal basis and storage period
3.1. Legal basis for the processing of personal data

If we obtain your consent for the processing of personal data, Art. 6 (1) a) DSGVO is the legal basis for the processing of personal data. Any consent can be revoked by you with effect for the future. When processing personal data that is necessary for the performance of a contract with you or your company, Art. 6 (1) b) DSGVO is the corresponding legal basis. This also applies to processing operations that already become relevant pre-contractually. If processing of your personal data is necessary to comply with one of our legal obligations, Art. 6 (1) c) DSGVO serves as the legal basis. If processing is necessary to protect a legitimate interest of our company or a third party and your interests, fundamental rights and freedoms do not outweigh our legitimate interest, Art. 6 (1) f) DSGVO serves as the legal basis for the processing.

3.2. Storage period and deletion of data

The personal data collected, processed and stored by us will only be stored by us for as long as the specific purpose of the storage requires. If the purpose of storage ceases to apply, your data will be deleted or its processing restricted. In addition, however, it may be that European regulations, applicable national laws or other regulations require us to store the data we process for a longer period. If these storage periods expire, we delete your data or restrict its processing.

4. Your rights

Insofar as we process your personal data, you are a "data subject" within the meaning of the GDPR. As a data subject, you have the following rights vis-à-vis instrAction:

4.1. Right of access regarding processing:

You can request information from us at any time within the framework of the legal provisions as to whether personal data is being processed by us. If this is the case, you have the right to request information about the scope of the data processing (cf. Art. 15 DSGVO).

4.2 Right of rectification

4.3. right to restriction of processing

If the conditions for this exist, you can demand the restriction of the processing of your personal data (cf. Art. 18 DSGVO).

4.4 Right of erasure

You can demand from intsrAction that the personal data concerning you be deleted without delay, provided that the conditions for this are met. The right to erasure does not exist insofar as the processing is necessary (cf. Art. 17 DSGVO).

4.5. Right to information

The controller shall notify all recipients to whom personal data have been disclosed of any rectification or erasure of the personal data or restriction of processing, unless this proves impossible or involves a disproportionate effort. The controller shall inform the data subject of these recipients if the data subject so requests (cf. Art. 19 GDPR).

4.6 Right to data portability

You have the right to receive the personal data concerning you that you have provided to instrAction in a structured, common and machine-readable format. In addition, you have the right to transfer this data to another company without hindrance from instrAction, to whom the personal data was provided, provided that the conditions for this exist (cf. Art. 20 DSGVO).

4.7. Right of objection

You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Art. 6(1)(f) DSGVO (cf. Art. 21(1) DSGVO). The consequence of the objection is that InstrAction will no longer process the personal data concerning you, unless InstrAction can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves the assertion, exercise or defence of legal claims. If the personal data concerning you is processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing (cf. Art. 21(2) DSGVO). Please address your objection to us (point 2 of this declaration).

4.8. Right to revoke the declaration of consent under data protection law

If you have given a declaration of consent under data protection law, you can revoke this at any time (cf. Art. 7 DSGVO). The revocation of consent does not affect the lawfulness of the processing carried out on the basis of the consent until the revocation.

4.9. Right to complain to a supervisory authority

Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your residence, place of work or place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR (cf. Art. 77 GDPR).

5. Visit to the instrAction website & creation of log files

Each time you visit our instrAction website, our system automatically collects data and information from your computer system. In particular, the following data is collected:

- Information about your browser type
- Information about your operating system
- Information about your internet service provider
- Your IP address
- Date and time of your visit to our site
- Information about the website from which your system accessed our website
- Information about the website accessed by your system through our website.

The aforementioned data we collect about you is stored in the log files of our system. This data is not stored together with other personal data. The legal basis for the temporary storage of the data and log files is Art. 6 para. 1 f) DSGVO. We have a legitimate interest in collecting and temporarily storing the aforementioned data, as the temporary storage of the IP address by the system is necessary to enable delivery of the website to your computer. The storage in log files is done to ensure the functionality of the website. In addition, this data is used to optimise our website and to ensure the security of our information technology systems. In the event that data is stored in log files, the data is deleted after seven days.

6. Contact with instrAction
6.1. E-mail

Our instrAction website contains an e-mail address which you can use to contact us. If you send us an e-mail, we will store your e-mail address and any other data you provide. The legal basis for the processing is Art. 6 (1) b) and f) DSGVO, as contacting us may involve initiating a contract. instrAction, however, also has a legitimate interest in processing your data in order to be able to respond to you. The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected and there are no legal or contractual archiving obligations that prevent deletion. The conversation is terminated when the circumstances indicate that the matter in question has been conclusively clarified. When you send your message, your IP address and the date and time of your contact are also stored. These other personal data processed during the sending process serve to prevent misuse of the e-mail and to ensure the security of our information technology systems. The additional personal data collected during the sending process will be deleted after a period of seven days at the latest. The data is used exclusively for processing the conversation. The legal basis for the processing of the data is Art. 6 para. 1 b) or f) DSGVO.

6.2. Contact form

There is a contact form on our instrAction website which you can use to contact instrAction electronically. If you use this option, the data entered in the input mask will be transmitted to us and stored. The legal basis for the processing of the data is Art. 6 Para. 1 b) or f) DSGVO. The processing of the personal data from the input mask of our contact form serves us - in addition to the above-mentioned purposes - solely to process your request, which is in our interest. This may involve, for example, the initiation of a contract. When you send your message, your IP address and the date and time of your contact are saved. These other personal data processed during the sending process serve to prevent misuse of the contact form and to ensure the security of our information technology systems. The additional personal data collected during the sending process will be deleted after a period of seven days at the latest. The data is used exclusively for processing the conversation. The legal basis for the processing of the data is Art. 6 para. 1 b) or f) DSGVO.

7. Use of cookies

No cookies are used.

8. Transfer to third parties
8.1. General information

We will generally only disclose your personal data to service providers, business partners and other third parties in accordance with applicable data protection laws. We may disclose personal data to service providers engaged by us and require them to process personal data on our behalf (commissioned processing). In the case of commissioned processing, we observe the strict applicable national and European data protection regulations. The processors are subject to our instructions and are subject to strict contractual restrictions with regard to the processing of personal data. We may also disclose personal data to other third parties if we are required to do so by law or legal process or in order to provide and manage our products and services. We may also be required to provide information to a law enforcement or other authority. We may also disclose information if it is necessary for us to cooperate with you in providing instrAction's services to you, or if you consent to such disclosure.

8.2. Hosting provider

Our servers, and therefore your data, are hosted by an external service provider, Host Europe GmbH, Hansestrasse 111, 51149 Cologne ("Host Europe"). Host Europe may only access your data within the scope of our instructions (order processing). Host Europe also takes strict technical measures to protect your personal data. Host Europe does not disclose your personal data to third parties unless the disclosure is necessary to perform the agreed services or Host Europe is required to do so to comply with the law or a valid and binding order of a governmental or regulatory authority. The data provided for this purpose will be kept to the minimum necessary. Host Europe stores all information exclusively on servers in Europe. Host Europe is subject to our instructions and is subject to strict contractual restrictions regarding the processing of personal data. Accordingly, processing is only permitted to the extent necessary to perform the services on our behalf or to comply with legal requirements. We will specify in advance exactly what rights and obligations our service providers should have in relation to personal data. The legal basis for the processing of your data is Art. 6 (1) f) DSGVO. The purpose of the data processing is for Host Europe to provide us with the opportunity to use the Host Europe servers. We only store your data for as long as it is necessary to achieve the purpose. You can find more information at https://www.hosteurope.de/AGB/Datenschutzerklaerung/.

8.3. Categories of recipients

Among others, we also pass on the data to the following recipients: Service providers for website design and maintenance
- Logistics service providers
- Lawyers

- Tax consultant

9. Disclosure of data to third parties, No data transfer to non-EU countries

Data transfer to bodies or persons outside the EU does not take place and is not planned.

10. Safety standards

instrAction has implemented appropriate physical, technical and administrative security standards to protect personal information from loss, misuse, alteration or destruction. Our service providers and affiliates are contractually obligated to maintain the confidentiality of personal data. In addition, they are not allowed to use the data for purposes not authorised by us.

11. Amendments to this Declaration

We may update this privacy statement from time to time. We therefore recommend that you review this privacy statement regularly so that you are aware of our privacy practices. This privacy statement was last updated on 31 October 2019.

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Data privacy

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