- General information about the collection of personal data
- Contact information relating to the data controller
- Notes on lawfulness and period of storage
- Your rights
- Visits to the instrAction website and creation of log files
- Contact with instrAction
- Disclosure to third parties
- Transfer of data to third parties; no transfer of data to non-EU countries
- Security standards
- Changes to this policy
1. General information about the collection of personal data
Personal data are all data which refer to you personally, including for example your form of address, name, address, e-mail address, IP address, etc. We only collect and process your personal data in compliance with the provisions of the EU General Data Protection Regulation (“GDPR”) and other provisions of European and applicable national data protection law.
Personal data are only collected and used on a regular basis with your consent or if the processing of such data is permitted by law. The following provisions provide information about the type, scope and purpose of the collection and processing of your personal data. In the event that for individual functions of our offer and/or our services we have recourse to commissioned service providers (third parties) or use your data for promotional or analysis purposes, we additionally provide you with detailed information below about the relevant data processing procedures. At this point we also inform you about the stipulated criteria for and the storage period. We also inform you about your rights regarding each data processing activity.
2. Contact data relating to the data controller
instrAction (“controller”) is responsible for data protection within the meaning of the GDPR and under all other applicable EU data protection law. If you have any questions, suggestions or criticisms relating to data protection and our website, please contact:
Telefon: +49 6221 650 99 46
3.Legitimacy of the processing and period of storage
3.1. Legal basis for the processing of personal data
The legal basis for processing operations affecting your personal data is your consent as stipulated in Article 6 (1) a) GDPR. You are entitled to withdraw any consent you have given at any time with effect for the future.
Under Article 6 (1) b) GDPR, the processing of your personal data is legitimate if such processing is necessary for the performance of a contract with you or your company. This also applies to all processing operations which are relevant prior to entering into a contract. The legal basis for processing which is necessary for compliance with our legal obligations is Article 6 (1) c) GDPR.
Article 6 (1) f) GDPR is the legal basis for processing which is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms.
3.2. Storage period and erasure of data
Any personal data which we collect, process and store will only ever be kept by us for as long as there is a specific purpose for such storage. Your data will be erased, or their processing restricted as soon as the specific purpose for which they were stored no longer applies.
It is possible, however, that European regulations, applicable national laws or other rules may require that we store data which we have processed for a longer period of time. We will erase or restrict the processing of your data when these statutory data retention periods have expired.
4. Your rights
For the purposes of the GDPR you are the data subject of any of your personal data which we process. As a data subject you have the following rights with regard to instrAction:
4.1. Right of access to the processing information by the data subject
You can at any time within the framework of the statutory provision request from us information as to whether personal data are processed by us. If this is the case, you have the right to be informed about the extent to which your personal data are being processed (Article 15 GDPR).
4.2 Right to rectification
You have the right to obtain from instrAction the rectification of inaccurate personal data concerning you and/or to have incomplete personal data completed (Article 16 GDPR).
4.3. Right to restriction of processing
In certain circumstances you have the right to have the processing of your personal data restricted (Article 18 GDPR).
4.4. Right to erasure
You have the right in certain circumstances to obtain from instrAction the erasure of personal data concerning you without undue delay. The right to erasure does not apply to the extent that processing is necessary (Article 17 GDPR).
4.5. Notification obligation regarding rectification or erasure of personal data or restriction of processing
The controller shall communicate any rectification or erasure of personal data or restriction of processing to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort. The controller shall inform the data subject about such recipients if requested by the data subject (Article 19 GDPR).
4.6. Right to data portability
You have the right to receive any personal data concerning you which you have provided to instrAction in a structured, commonly used and machine-readable format. You also have the right in certain circumstances to transmit those data to another company without hindrance from instrAction to which the personal data have been provided (Article 20 GDPR).
4.7. Right to object
You have the right to object, on grounds relating to your particular situation, at any time to the processing of personal data concerning you based on Article 6 (1) sentence 1 f) GDPR. instrAction may then no longer process the personal data relating to you unless instrAction demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.
4.8. Right to withdraw the declaration of consent under data protection law
You have the right to withdraw at any time any declaration of consent you have submitted under data protection law (Article 7 GDPR). Withdrawal of consent does not affect the legitimation of any processing conducted on the basis of the consent up to the point of withdrawal.
4.9. Right to lodge a complaint with 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 habitual residence, place of work or place of the alleged infringement if you consider that the processing of personal data relating to you infringes the GDPR (Article 77 GDPR).
5. Visits to the instrAction website and creation of log files
Our system automatically retrieves data and information from your computer system each time you visit our instrAction website. The following data in particular are collected then:
- Information about the type of browser you are using;
- Information about your operating system;
- Information about your internet service provider;
- Your IP address
- Date and time of your visit to our website;
- Information about the website from which your system has reached our website;
- Information about the website which is called up by your system via our website.
The legitimation for the temporary storage of data and log files is Article 6 (1) f) GDPR. We have a legitimate interest in collecting and temporarily storing the data referred to as the IP address must be stored temporarily by the system in order to provide the website to your computer.
Data are stored in log files to ensure the functioning of the website. This information is also used to optimise our website and to guarantee the security of our information technology systems.
Data which are stored in log files are erased after seven days.
6. Contact with instrAction
An e-mail address has been stated on our website which you can use to make contact with us. If you write an e-mail to us, we will store your e-mail address with other data which you have provided.
The legitimation for processing is Article 6 (1) b) and f) GDPR as contact may be made for the purpose of initiating a contract. instrAction also has a legitimate interest in processing your data for the purpose of sending you an answer. The data are erased as soon as they are no longer required for the purpose for which they have been collected and provided that they are not subject to any legal or contractual archiving obligations. The conversation has come to an end when it is apparent from the circumstances that the matter being discussed has been finally clarified.
Your IP address and the date on and time at which you made contact with us are also stored when you send your message. Other personal data processed during the transmission operation are used to prevent the e-mail from being misused and to ensure the security of our information technology systems. Other personal data collected during transmission will be erased after a period of seven days at the latest. The data are used exclusively to process the conversation. The legal basis for the processing of data is Article 6 (1) b) or f) GDPR.
6.2. Contact form
You can make contact with instrAction by electronic means using the contact form on our instrAction website. If you wish to contact us in this way, the data which you enter will be sent to us and stored.
The legal basis for the processing of data is Article 6 (1) b) or f) GDPR. We only process any personal data which you enter in our contact form for the purposes referred to above or to deal with your request, which is in our interest. This may, for example, involve the initiation of a contract.
Your IP address and the date on and time at which you made contact with us are also stored when you send your message. Other personal data processed during the transmission operation are used to prevent the contact form from being misused and to ensure the security of our information technology systems. Other personal data collected during transmission will be erased after a period of seven days at the latest. The data are used exclusively to process the conversation. The legal basis for the processing of data is Article 6 (1) b) or f) GDPR.
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8. Disclosure to third parties
8.1. General information
As a rule, we will only pass on your personal data in compliance with the applicable data protection laws to service providers, business partners and other third parties.
We may disclose personal data to service providers working on our behalf and require them to perform services in our name (order processing). We comply with stringent national and European data protection regulations on commissioned data processing. Processors are bound by our instructions and are subject to stringent contractual limitations on the processing of personal data.
We may also disclose personal data to a third party if we are required to do so by law or in legal proceedings or in order to supply and manage our products and services. We may also be required to provide information to law enforcement agencies or other public authorities. We are also authorised to release data if the disclosure of information is necessary for the purposes of collaboration and thus of providing instrAction's services to you or if you declare your consent to such disclosure.
8.2. Hosting provider
Our server, and therefore your data as well, 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 framework of our instructions (commissioned data processing). Host Europe also takes strict technical measures to protect your personal data. Host Europe will not pass on your personal data to third parties except where it is necessary to pass them on to render the agreed services or Host Service is obligated to do so to comply with the law or a valid and mandatory instruction of a government or regulatory agency. The data provided for this purpose are kept to a minimum. Host Europe stores all information exclusively on servers in Europe.
Host Europe is bound by our instructions and is subject to stringent contractual limitations on the processing of personal data. In accordance with this, processing is only permitted if it is necessary to perform the services in our name or to adhere to legal requirements. We establish precisely in advance what rights and obligations our service providers are to have with regard to personal data.
The legal basis for the processing of your data is Article 6 (1) f) GDPR. The purpose of the data processing is for Host Europe to offer us the opportunity to use its servers. We only store the data for as long as is necessary to achieve this purpose. More information is available at https://www.hosteurope.de/en/terms-and-conditions/privacy/
8.3. Categories of recipient
We also pass on the data to recipients which include:
- Website design and maintenance service providers
- Logistics service providers;
- Tax consultants
9. Transfer of data to third parties; no transfer of data to non-EU countries
Data are not sent, nor are there any plans to send data, to functions or persons outside the EU.
10. Security standards
instrAction has implemented appropriate physical, technical and administrative security standards to protect personal data against loss, misuse, modification or destruction. Our service providers and associated undertakings are contractually committed to safeguarding the confidentiality of personal data. They are also prohibited from using data for purposes not approved by us.
11. Changes to this policy