Privacy Policy

Thank you for visiting our website. Compliance with data protection regulations is of particular importance to us. The purpose of this privacy policy is to inform you as a user of the website about the type, scope, and purpose of the processing of personal data and the rights available to you, as far as you are considered a data subject within the meaning of Art. 4 No. 1 of the General Data Protection Regulation. This privacy policy already takes into account the changes pursuant to the General Data Protection Regulation (GDPR) applicable from May 25, 2018. At the same time, this statement also fulfills the requirements valid until then under § 13 of the Telemedia Act.

1. Responsible Entity

This website and the service offerings are operated by

Inspirion GmbH
Inspirionstraße 2
27367 Sottrum
Germany

Tel: +49 4264 7384-000
Fax: +49 4264 7384-013
Email: info@inspirion.eu
Web: mypromotiontops.de

Managing Director: Sönke Hinrichs.

2. General

We have designed the development of the website to collect as little data as possible from you. In general, it is possible to visit our website without providing personal data. Only when you decide to log in with your login details is the processing of personal data necessary. We always ensure that your personal data is processed only in accordance with a legal basis or your consent. We comply with the provisions of the General Data Protection Regulation (GDPR) applicable from May 25, 2018, and the respective national regulations, such as the Federal Data Protection Act, the Telemedia Act, or other specific laws on data protection.

3. Definition

The terms used in this Privacy Policy have the following meaning in accordance with the GDPR.

“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, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;

“processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

“restriction of processing” means the marking of stored personal data with the aim of limiting their processing in the future;

“pseudonymisation” 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 organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person;

“controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the 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;

“processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;

“recipient” means a natural or legal person, public authority, agency or other body to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing;

“third party” means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data;

“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.

4. Purpose and Legal Basis for Processing Personal Data

Personal data necessary for the establishment, performance, or management of our service offerings are processed on the legal basis of Art. 6 Para. 1 lit. b GDPR. Where we employ external service providers in the context of data processing, processing is based on the legal basis of Art. 28 GDPR.
The personal data are collected, processed, and used exclusively for the following purposes:

Purpose of Data Processing	Legal Basis for Data Processing (“Why is the Data Processing Necessary”)
to ensure that our downloads are not misused	on the basis of legitimate interests
for the technical realization of our offerings	on the basis of legitimate interests

5. Collected and Processed Personal Data

We collect and process your personal data only if you voluntarily provide it with your knowledge, such as by registering for our download portal.

In the context of the available service, the following data are initially:
Data when using the download portal:

• Email address
• Customer number

Furthermore, for our security, after registration, we store the timestamp, customer number, IP address, and filenames of the downloaded files.
The personal data provided by you and their content remain exclusively with us and our affiliated companies. We will store and process your data only for the purposes mentioned in No. 5. Use beyond the indicated purpose requires your express consent. The same applies for the transfer and transmission of your data to third parties.

6. General Log Files

The web server temporarily records the connection data of the requesting computer (IP address), the pages you visit on our site, the date and duration of your visit, the detection data of the browser and operating system type used, and the website from which you visit us as well as the successful retrieval in log files (log files). The technical administration of the websites and anonymous statistical surveys enable an analysis of the accesses to Inspirion's offering and an evaluation with the aim of increasing data protection and data security in our company, ultimately to ensure an optimal level of protection for the personal data we process.
The data of the server log files are stored separately from all personal data provided by you.

7. Cookies

Use of Cookies
Information is collected and stored on our website through the use of so-called browser cookies.

What are cookies?
These are small text files that are stored on your data carrier and that store certain settings and data for exchange with our system via your browser. A cookie typically contains the name of the domain from which the cookie data was sent as well as information about the age of the cookie and an alphanumeric identification mark.

Why do we use cookies?
Cookies enable our systems to recognize the user's device and to make any preferences immediately available. As soon as a user accesses the platform, a cookie is transmitted to the hard drive of the user's computer. Cookies help us to improve our website and to offer you a better and more personalized service. They allow us to recognize your computer or (mobile) device when you return to our website, thereby:

• Aligning our website with your individual interests.

You can find a list of the cookies we set in the following table:

Cookie Name	First-party Cookies or Third-party Cookie? If third-party cookie: Who is the provider?	Description / Function	Standard Expiration Time
ASP.NET_SessionID	First-party	Session Cookie	End of session
cookieconsent_dismissed	First-party	Cookie notification cookie	365 days

Can I control the use of cookies?
If you do not wish to use browser cookies, you can set your browser so that the storage of cookies is not accepted. Please be aware that in this case you may only be able to use our website to a limited extent or not at all. If you want to accept only our own cookies, but not the cookies of our service providers and partners, you can select the setting in your browser "Block third-party cookies". We accept no responsibility for the use of third-party cookies.

8. Data Security

Unfortunately, the transmission of information over the Internet is never 100% secure, which is why we cannot guarantee the security of data transmitted to our website over the Internet.

However, we secure our website through technical and organizational measures against loss, destruction, access, alteration, or distribution of your data by unauthorized persons.

In particular, your personal data is transmitted encrypted. We use the coding system SSL/TLS (Secure Sockets Layer/ Transport Layer Security). Our security measures are continuously improved in line with technological developments.

9. Rights of the Data Subject

Insofar as you are considered a data subject within the meaning of Art. 4 No. 1 GDPR, you have the following rights regarding the processing of your personal data under the GDPR. The legal text of the rights listed below can be found at
https://www.bfdi.bund.de/SharedDocs/Publikationen/Infobroschueren/INFO6.html.


Right to Confirmation and Access
Under the conditions of Art. 15 GDPR, you have the right to request confirmation as to whether personal data concerning you is being processed and at any time to obtain free information about the personal data stored about you and a copy of this information from the controller.


Right to Rectification
Under the conditions of Art. 16 GDPR, you have the right to demand immediate rectification of inaccurate personal data concerning you. Furthermore, taking into account the purposes of the processing, you have the right to request the completion of incomplete personal data — also by means of providing a supplementary statement.


Right to Erasure
Under the conditions of Art. 17 GDPR, you have the right to demand that the personal data concerning you be erased immediately, provided that one of the reasons specified in Art. 17 GDPR applies and insofar as the processing is not necessary.


Right to Restriction of Processing
Under the conditions of Art. 18 GDPR, you have the right to demand the restriction of processing if one of the conditions specified in Art. 18 GDPR applies.


Right to Data Portability
Under the conditions of Art. 20 GDPR, you have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used, and machine-readable format, and you have the right to transmit those data to another controller without hindrance from us, provided that the further conditions of Art. 20 GDPR are met.


Right to Withdraw Consent
You have the right to withdraw consent to the processing of personal data at any time with effect for the future. Please address your revocation to the contact details given above.


Right to Object
Under the conditions of Art. 21 GDPR, you have the right to object at any time to the processing of personal data concerning you. If the conditions for an effective objection are met, processing by us may no longer take place.


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 residence, place of work or place of the alleged infringement, if you believe that the processing of personal data concerning you infringes the GDPR.

10. Transfer of Your Personal Data

The transfer of your personal data is as described below.
The hosting of the website takes place in Europe. Here, we ensure that data processing is carried out solely in Europe. This is necessary for the operation of the website, as well as for the establishment, execution, and handling of the existing usage contract and can be done without your consent.
A transfer also takes place when we are authorized or obliged to transfer data due to legal regulations and/or official or judicial orders. This can particularly be the case for providing information for the purposes of law enforcement, averting danger or enforcing intellectual property rights.
Insofar as your data is transferred to the necessary extent to service providers, they only have access to your personal data to the extent necessary to fulfill their tasks. These service providers are obligated to treat your personal data in accordance with the applicable data protection laws, particularly the GDPR.
Apart from the aforementioned circumstances, we generally do not transmit your data to third parties without your consent. In particular, we do not transfer personal data to a third country or an international organization.

11. Storage Duration for Personal Data

Regarding the storage duration, we delete personal data as soon as their storage is no longer necessary for the fulfillment of the original purpose and there are no longer any legal retention periods. The legal retention periods ultimately constitute the criterion for the final duration of the storage of personal data. After the expiration of these periods, the corresponding data is routinely deleted. If there are retention periods, processing is restricted by blocking the data.

12. References and Links

When accessing internet pages referred to within our website, information such as name, address, email address, browser properties, etc. may be requested again. This Privacy Policy does not govern the collection, transmission, or handling of personal data by third parties.

Third-party service providers may have different and own provisions in the handling of the collection, processing, and use of personal data. Therefore, it is advisable to inform oneself about their practices in handling personal data on the websites of third parties before entering personal data.

13. Changes to the Privacy Policy

We continuously develop our website to provide you with an ever-improving service. We will always keep this privacy policy up to date and adjust it as necessary.
We will of course inform you about any changes to this privacy policy in good time. We will do this, for example, by sending an email to the email address you have provided to us. Insofar as further consent from you to our handling of your data is required, we will of course obtain this from you before any corresponding changes take effect.
You can retrieve the current version of our privacy policy at any time on the internet at https://mypromotiontops.de/default.aspx?page=privacy.

14. Data Protection Officer

If you have any questions about data protection, please contact our data protection officer.

Herold Unternehmensberatung GmbH
Mr. Marco Haß
Hafenstraße 1a
23568 Lübeck

E-mail: privacy-officer[at]inspirion.eu
Web: www.mein-datenschutzbeauftragter.de

Date: May 2018