Privacy Policy


Introduction


With the following privacy policy, we would like to inform you about which types of your personal data (hereinafter also referred to as "data") we process, for what purposes, and to what extent. This privacy policy applies to all processing of personal data carried out by us, both in the context of the provision of our services and in particular on our websites, in mobile applications, and within external online presences, such as our social media profiles (hereinafter collectively referred to as "online offering").

The terms used are not gender-specific.

As of: December 8, 2021


Table of Contents



Person responsible


Michael Hoofdmann
Rosenstr.19
27639 Wurster North Sea coast

Germany

E-mail address: kontakt@hoofdmann-consulting.de.

Link to the imprint: www.hoofdmann-consulting.de/impressum


Overview of processing


The following overview summarizes the types of data processed and the purposes of their processing and refers to the data subjects.


Types of data processed


  • Content data (e.g. entries in online forms).
  • Contact details (e.g. email, telephone numbers).
  • Meta/communication data (e.g. device information, IP addresses).
  • Usage data (e.g. websites visited, interest in content, access times).

    • Categories of data subjects


    • Users (e.g. website visitors, users of online services).

      • Purposes of processing


      • Provision of our online offering and user-friendliness.
      • Feedback (e.g. collecting feedback via online form).
      • Marketing.
      • Contact requests and communication.

        • Relevant legal bases


        Below you will find an overview of the GDPR legal bases on which we process personal data. Please note that in addition to the GDPR regulations, national data protection regulations may apply in your or our country of residence or domicile. Should more specific legal bases apply in individual cases, we will inform you of these in the privacy policy.

        • Legitimate interests (Art. 6 (1) (f) GDPR) - Processing is necessary to protect the legitimate interests of the controller or a third party, unless the interests or fundamental rights and freedoms of the data subject which require protection of personal data prevail.

          National data protection regulations in Germany: In addition to the data protection regulations of the General Data Protection Regulation, national data protection regulations apply in Germany. This includes, in particular, the Federal Data Protection Act (BDSG). The BDSG contains, in particular, special provisions on the right to information, the right to erasure, the right of objection, the processing of special categories of personal data, processing for other purposes, and transmission and automated decision-making in individual cases, including profiling. Furthermore, it regulates data processing for the purposes of the employment relationship (Section 26 BDSG), particularly with regard to the establishment, implementation, or termination of employment relationships and the consent of employees. Furthermore, state data protection laws of the individual federal states may apply.


          Security measures


          In accordance with the legal requirements, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons, we take appropriate technical and organisational measures to ensure a level of protection appropriate to the risk.

          These measures include, in particular, ensuring the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data, as well as the access, input, and transfer of data, ensuring its availability, and segregation. Furthermore, we have established procedures that ensure the exercise of data subjects' rights, the deletion of data, and responses to data threats. Furthermore, we consider the protection of personal data right from the development and selection of hardware, software, and processes in accordance with the principle of data protection, through technology design, and through data protection-friendly default settings.

          SSL encryption (https): To protect the data you transmit via our online service, we use SSL encryption. You can recognize such encrypted connections by the prefix https:// in your browser's address bar.


          Cooperation with processors and third parties


          If, as part of our processing, we disclose data to other persons and companies (contract processors or third parties), transmit it to them or otherwise grant them access to the data, this will only be done on the basis of legal permission (e.g. if transmission of the data to third parties, such as payment service providers, is necessary to fulfil the contract in accordance with Art. 6 (1) (b) GDPR), you have consented, a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).

          If we commission third parties to process data on the basis of a so-called "order processing agreement", this is done on the basis of Art. 28 GDPR.


          Google Fonts


          We integrate the fonts ("Google Fonts") of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy Policy:https://www.google.com/policies/privacy/, Opt-Out:https://adssettings.google.com/authenticated.



          Transmission of personal data


          As part of our processing of personal data, it may happen that the data is transmitted to or disclosed to other bodies, companies, legally independent organizational units, or individuals. Recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content integrated into a website. In such cases, we comply with legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data that serve to protect your data.


          Data processing in third countries


          If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA)) or if the processing takes place in the context of the use of third-party services or the disclosure or transmission of data to other persons, bodies or companies, this will only be done in accordance with the legal requirements.

          Subject to express consent or contractually or legally required transmission, we process or have the data processed only in third countries with a recognized level of data protection, contractual obligation through so-called standard protection clauses of the EU Commission, in the presence of certifications or binding internal data protection regulations (Art. 44 to 49 GDPR, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_en).


          Deletion of data


          The data we process will be deleted in accordance with legal requirements as soon as the consent to processing is revoked or other permissions no longer apply (e.g. if the purpose of processing this data no longer applies or it is no longer required for the purpose).

          Unless the data is deleted because it is required for other legally permissible purposes, its processing will be limited to these purposes. This means that the data will be blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons, or whose storage is necessary to assert, exercise, or defend legal claims or to protect the rights of another natural or legal person.

          Our privacy policy may also contain further information on the storage and deletion of data, which applies primarily to the respective processing operations.


          Use of cookies


          Cookies are small text files or other storage devices that store information on end devices and read information from end devices. For example, they can store the login status in a user account, the contents of a shopping cart in an e-shop, the content accessed, or the functions used in an online offering. Cookies can also be used for various purposes, such as improving the functionality, security, and convenience of online offerings, as well as creating analyses of visitor flows.

          Notes on consent: We use cookies in accordance with legal regulations. Therefore, we obtain prior consent from users, unless this is not required by law. Consent is particularly unnecessary if the storage and retrieval of information, including cookies, is absolutely necessary to provide users with a telemedia service they have expressly requested (i.e., our online offering). The revocable consent will be clearly communicated to users and will contain information about the respective cookie usage.

          Notes on data protection legal bases: The data protection legal basis on which we process users' personal data with the help of cookies depends on whether we ask users for consent. If users consent, the legal basis for processing their data is their declared consent. Otherwise, the data processed with the help of cookies is processed on the basis of our legitimate interests (e.g. in the commercial operation of our online offering and improving its usability) or, if this occurs as part of the fulfillment of our contractual obligations, if the use of cookies is necessary to fulfill our contractual obligations. We explain the purposes for which we process cookies in the course of this data protection declaration or as part of our consent and processing processes.

          Storage period: With regard to the storage period, the following types of cookies are distinguished:

          • Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offering and closed his or her device (e.g. browser or mobile application).
          • Persistent cookies: Persistent cookies remain stored even after the device is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. Likewise, the user data collected through cookies can be used to measure reach. Unless we provide users with explicit information about the type and storage period of cookies (e.g., when obtaining consent), users should assume that cookies are permanent and can be stored for up to two years.

            • General information on revocation and objection (opt-out): Users can revoke their consent at any time and also object to processing in accordance with the legal requirements of Art. 21 GDPR (further information on objection is provided in this privacy policy). Users can also declare their objection using their browser settings.

            Processing of cookie data based on consent: We use a cookie consent management procedure within which users' consent to the use of cookies or the processing operations and providers named in the cookie consent management procedure can be obtained, managed and revoked by users. The declaration of consent is saved so that it does not have to be requested again and so that consent can be proven in accordance with legal obligations. Storage can take place on the server side and/or in a cookie (so-called opt-in cookie or with the help of comparable technologies) in order to be able to assign consent to a user or their device. Subject to individual information about the providers of cookie management services, the following information applies: Consent can be stored for up to two years. A pseudonymous user identifier is created and stored along with the time of consent, information on the scope of the consent (e.g. which categories of cookies and/or service providers) as well as the browser, system and device used.

            Usercentrics:

            Services and service providers used:

            • 1379020712.272152 838086833.0964409 826282950.9003359 1091347696.9762204 1130317959.8010404 2150946183.718894 1491094932.3121018 17263208999.92857 785768803.7845304 1248474937.6716173 1390280272.7761905 239497235.94278607 701097484.3227017 1092638922.0042918 1123953152.2238562 197780212.96301776 1004209181.998679 675782436.6335404 12065235525.394737 1198770007.4476843

              • Provision of the online offer and web hosting


              In order to provide our online offering securely and efficiently, we utilize the services of one or more web hosting providers, from whose servers (or servers managed by them) the online offering can be accessed. For these purposes, we may use infrastructure and platform services, computing capacity, storage space, and database services, as well as security and technical maintenance services.

              The data processed in the context of providing the hosting service may include all information concerning the users of our online offering that arises during use and communication. This usually includes the IP address, which is necessary to deliver the content of online offerings to browsers, and all entries made within our online offering or on websites.

              Email sending and hosting: The web hosting services we use also include the sending, receiving, and storing of emails. For these purposes, the addresses of the recipients and senders, as well as other information relating to the email sending (e.g., the providers involved), and the content of the respective emails are processed. The aforementioned data may also be processed for the purposes of detecting SPAM. Please note that emails are generally not sent encrypted over the Internet. Emails are generally encrypted during transport, but (unless a so-called end-to-end encryption method is used) not on the servers from which they are sent and received. We therefore cannot accept any responsibility for the transmission path of the emails between the sender and the recipient on our server.

              Collection of access data and log files: We ourselves (or our web hosting provider) collect data on every access to the server (so-called server log files). Server log files may include the address and name of the accessed web pages and files, the date and time of access, the amount of data transferred, notification of successful access, browser type and version, the user's operating system, the referrer URL (the previously visited page), and, as a rule, IP addresses and the requesting provider.

              The server log files can be used for security purposes, e.g. to avoid overloading the servers (particularly in the case of abusive attacks, so-called DDoS attacks) and to ensure the utilization of the servers and their stability.

              United Domains:

              • Types of data processed: Content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
              • Data subjects: Users (e.g. website visitors, users of online services).
              • Purposes of processing: Provision of our online services and user-friendliness.
              • Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR).

                • Services and service providers used:

                • 367538539.1450839 24622409843.97059 2522987754.3587785 530279401.75073314 1450775588.8971963 1377725482.719325 517340819.911859 77136128.98859935 679501021.6136364 939746867.1439394 582611589.8391867 901831850.3065902 688598145.8325435 211407357.65300897 37091924.56868132 8881121476.637363 224508006.49751243 559917595.5086093 144198808.9379391 11398173002.232557

                  • Presences in social networks (social media)


                  We maintain online presences within social networks and, in this context, process user data in order to communicate with the users active there or to offer information about us.

                  We would like to point out that user data may be processed outside the European Union. This could pose risks for users, for example, because it could make it more difficult to enforce their rights.

                  Furthermore, user data within social networks is generally processed for market research and advertising purposes. For example, user profiles can be created based on user behavior and the resulting interests of the users. These user profiles can then be used, for example, to place advertisements within and outside the networks that presumably correspond to the interests of the users. For these purposes, cookies are generally stored on users' computers in which the user behavior and interests are saved. Furthermore, user profiles can also store data independent of the devices used by the users (particularly if the users are members of the respective platforms and are logged in to them).

                  For a detailed description of the respective processing methods and the options for opting out, please refer to the privacy policies and information provided by the operators of the respective networks.

                  In the case of requests for information and the assertion of data subject rights, we would like to point out that these can be most effectively asserted with the providers. Only the providers have access to the user data and can directly take appropriate measures and provide information. If you still need assistance, please contact us.

                  • Types of data processed: Contact data (e.g. email, telephone numbers), content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
                  • Data subjects: Users (e.g. website visitors, users of online services).
                  • Purposes of processing: contact requests and communication, feedback (e.g. collecting feedback via online form), marketing.
                  • Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR).

                    • Services and service providers used:

                    • LinkedIn: Social network; Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Website: https://www.linkedin.com; Privacy Policy: https://www.linkedin.com/legal/privacy-policy; Standard contractual clauses (guaranteeing data protection levels when processing in third countries): https://legal.linkedin.com/dpa; Possibility of objection (opt-out): https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out; Data processing agreement: https://legal.linkedin.com/dpa.
                    • Xing: Social network; Service provider: XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany; Website: https://www.xing.de; Privacy Policy: https://privacy.xing.com/de/datenschutzerklaerung.

                      • Services offered


                      We process the data of our clients and interested parties and other clients or contractual partners (collectively referred to as "clients") in accordance with Art. 6 (1) (b) GDPR in order to provide them with our contractual or pre-contractual services. The data processed in this process, the type, scope, purpose, and necessity of their processing are determined by the underlying contractual relationship. The data processed generally includes client inventory and master data (e.g., name, address, etc.), as well as contact details (e.g., email address, telephone, etc.), contract data (e.g., services used, fees, names of contact persons, etc.), and payment data (e.g., bank details, payment history, etc.).

                      As part of our services, we may also process special categories of data pursuant to Art. 9 (1) GDPR, in particular information about clients' health, possibly with reference to their sex life or sexual orientation, ethnic origin, or religious or ideological beliefs. For this purpose, we will obtain the client's express consent, where necessary, in accordance with Art. 6 (1) (a), Art. 7, and Art. 9 (2) (a) GDPR. Otherwise, we process the special categories of data for the purposes of healthcare on the basis of Art. 9 (2) (h) GDPR and Section 22 (1) No. 1 (b) BDSG.

                      If required for the fulfilment of the contract or by law, we will disclose or transmit client data as part of our communication with other specialists, to third parties who are necessarily or typically involved in the fulfilment of the contract, such as billing offices or similar service providers, provided that this serves the provision of our services in accordance with Art. 6 (1) (b) GDPR, is prescribed by law in accordance with Art. 6 (1) (c) GDPR, serves our interests or those of the client in efficient and cost-effective healthcare as a legitimate interest in accordance with Art. 6 (1) (f) GDPR or is necessary in accordance with Art. 6 (1) (d) GDPR, to protect the vital interests of the client or another natural person or within the framework of consent in accordance with Art. 6 (1) (a) and Art. 7 GDPR.

                      Data will be deleted when it is no longer required to fulfill contractual or statutory duties of care or to deal with any warranty or similar obligations. The necessity of retaining the data will be reviewed every three years; otherwise, statutory retention periods apply.


                      Administration, financial accounting, office organization, contact management


                      We process data as part of administrative tasks and to organize our operations, financial accounting, and to comply with legal obligations, such as archiving. In doing so, we process the same data that we process as part of providing our contractual services. The processing is based on Art. 6 (1) (c) GDPR and Art. 6 (1) (f) GDPR. Customers, interested parties, business partners, and website visitors are affected by the processing. The purpose of and our interest in the processing lies in administration, financial accounting, office organization, and data archiving—i.e., tasks that serve to maintain our business activities, perform our duties, and provide our services. The deletion of data for contractual services and contractual communication corresponds to the information provided for these processing activities.

                      We disclose or transmit data to the tax authorities, consultants such as tax consultants or auditors as well as other fee offices and payment service providers.

                      Furthermore, based on our business interests, we store information about suppliers, event organizers, and other business partners, e.g., for the purpose of later contact. We generally store this mostly company-related data permanently.


                      Contact us


                      When you contact us (e.g., via contact form, email, telephone, or social media), the user's information will be processed to process the contact request and its handling in accordance with Art. 6 (1) (b) GDPR. User information may be stored in a customer relationship management system ("CRM system") or similar request organization.

                      We delete requests if they are no longer required. We review their necessity every two years; furthermore, statutory archiving obligations apply.


                      Changes and updates to the privacy policy


                      We ask you to inform yourself regularly about the content of our privacy policy. We will adapt the privacy policy as soon as changes to the data processing we carry out make this necessary. We will inform you as soon as the changes require your cooperation (e.g., consent) or other individual notification.

                      If we provide addresses and contact information of companies and organizations in this privacy policy, please note that the addresses may change over time and ask you to check the information before contacting us.


                      Rights of data subjects


                      As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Articles 15 to 21 GDPR:

                      • Right of objection: You have the right to object at any time to the processing of personal data concerning you based on Art. 6 (1) (e) or (f) GDPR, for reasons related to your particular situation; this also applies to profiling based on these provisions. If the personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for the purposes of such advertising; this also applies to profiling insofar as it is related to such direct marketing.
                      • Right to withdraw consent: You have the right to withdraw consent at any time.
                      • Right to information: You have the right to request confirmation as to whether the data in question is being processed and to request information about this data as well as further information and a copy of the data in accordance with the legal requirements.
                      • Right to rectification: You have the right, in accordance with the statutory provisions, to request that the data concerning you be completed or that inaccurate data concerning you be corrected.
                      • Right to erasure and restriction of processing: You have the right, in accordance with the statutory provisions, to demand that data concerning you be erased immediately or, alternatively, to demand that the processing of the data be restricted in accordance with the statutory provisions.
                      • Right to data portability: You have the right to receive the data concerning you that you have provided to us in a structured, common and machine-readable format in accordance with the legal requirements or to request that it be transmitted to another controller.
                      • Complaint 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 habitual residence, place of work or place of the alleged infringement, if you consider that the processing of personal data concerning you violates the provisions of the GDPR.

                        • Definitions of terms


                        This section provides an overview of the terms used in this privacy policy. Many of the terms are taken from the law and are defined primarily in Art. 4 GDPR. The legal definitions are binding. The following explanations, however, are primarily intended to facilitate understanding. The terms are sorted alphabetically.

                        • 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, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. a cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
                        • Controller: The “controller” 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.
                        • Processing: "Processing" is any operation or set of operations performed on personal data, whether or not by automated means. The term is broad and encompasses virtually any handling of data, whether it involves collecting, analyzing, storing, transmitting, or deleting.



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