Privacy Policy

Preface

This policy sets out the different areas where user privacy is concerned and outlines the obligations and requirements of Steven Hunt & Associates and users of this website. Furthermore, the way this website processes, stores and protects user data and information will also be detailed within this policy. Steven Hunt & Associates collects, stores or processes data only for the purpose of carrying out its own business purposes. The following explains how we handle your personal data and what rights you have.

 

This website can be used without providing any personal data. However, if you wish to take advantage of special services offered by our company via our website, it may be necessary to process personal data. If it is necessary to process personal data and there is no legal basis for such processing, we generally obtain the consent of the person concerned (the purposes and legal basis of processing are listed below).

 

As the data controller, Steven Hunt has implemented numerous technical and administrative measures in order to ensure the most complete protection possible for the personal data processed. Nevertheless, internet-based data transfer may have security vulnerabilities that make it impossible to guarantee absolute protection. For this reason, each data subject is free to transmit personal data to us by alternative means, such as by telephone.

 

 

Definitions

Steven Hunt & Associates’ privacy notices are based on the terminology used by the European regulators when the General Data Protection Regulation (GDPR) was adopted. Our privacy notices are designed to be easy to read and understand for the public as well as for our customers and business partners. To ensure this, we wish to explain the terms we use in advance.

 

We use the following terms, among others, in this privacy notice:

  • “Personal data” means any information relating to an identified or identifiable natural person (hereinafter referred to as “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, on-line identifier, or to one or more special characteristics specific to the physical, physiological, genetic, mental, commercial or cultural or social identity of that natural person.
  • “Data subject” means any identified or identifiable natural person whose personal data are processed by the controller.
  • 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, organization, 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.
  • The controller or person in control of processing 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 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 framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients.
  • 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 authorized 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.

 

 

Name and Contact Details of the Controller

The controller within the meaning of the General Data Protection Regulation, other data protection laws applicable in the Member States of the European Union and other provisions of a data protection nature is:

Address: Steven Hunt, Steven Hunt & Associates, An der Sandkuhle, An der Sandkuhle 34, 45659 Recklinghausen, Germany.

Tel.: 0049 2361 3703490
E-mail: privacy@stevenhunt.net
Website: www.stevenhunt.net

 

 

Your Rights

You have the right to request information about the personal data stored by us free of charge and/or to demand correction, blocking or deletion. Exceptions: data subject to the prescribed data storage for business purposes or data subject to the statutory retention obligation.

 

In order to accommodate data blocking at any time, it is necessary to keep the data in a blocked file for control purposes. If there is no legal archiving obligation, you can also request that the data be deleted. Otherwise, we will block the data if you so wish.

 

You have the right to object at any time to the processing of your personal data carried out on the basis of our legitimate interests. In the event of an objection, Steven Hunt & Associates will no longer process your personal data for the purposes of our legitimate interests, including direct marketing.

 

Furthermore, you have the right to revoke your consent to the processing of personal data at any time and free of charge. This revocation can be made by telephone, or directly on our website via the corresponding link in every newsletter, or by e-mail to privacy@stevenhunt.net. We will then discontinue processing based on the consent up to this point.

 

We will process your request immediately and will honor your request no later than one month after receiving it.

 

If you believe that the processing of your data violates data protection law or your data protection rights have otherwise been violated in any way, you may lodge a complaint with the supervisory authority responsible:

Landesbeauftragte für Datenschutz und Informationsfreiheit
Nordrhein-Westfalen
Postfach 20 04 44
40102 Düsseldorf

Tel.: 0211/38424-0
Fax: 0211/38424-10
E-mail: poststelle@ldi.nrw.de

 

 

Purposes and Legal Basis of Processing Activity

 

Processing Orders in the Web Shop

If you order items in the web shop, we need your personal data. For the purpose of order processing, we collect and process your name and address (in the case of physical products such as books) or your name and e-mail (in the case of non-physical products such as white papers). The legal basis for this is the necessity to fulfill the contract in accordance with art. 6 para. 1 lit. b) GDPR.

 

In principle, the data is only passed on to third parties if this is necessary to fulfill the above-mentioned purposes. For example, a parcel service provider could be such a company, which also uses the personal data exclusively for the fulfillment of the above-mentioned purpose.

 

 

Contact Initiated by the Data Subject

If you contact Steven Hunt & Associates  via e-mail, the contact form on the website or via social media with Steven Hunt & Associates , we will store the information you provide for the purpose of processing your request and for possible follow-up questions. The legal basis for this is our legitimate interest according to art. 6 para. 1 lit. f) GDPR – namely the continuation of the dialogue initiated by you. This personal data will not be passed on to third parties.

 

 

Newsletter and Dialogue

On the Steven Hunt & Associates website, users are offered the opportunity to subscribe to newsletters. For this purpose we need your name and e-mail address. You can only receive the newsletters if you explicitly agree to receive them.

 

We use the personal data you provide us to send our newsletters by e-mail and for the purpose of relationship management and direct marketing by e-mail, postal mail or telephone. The legal basis for this is your consent in accordance with art. 6 para. 1 lit. a) GDPR.

 

You can revoke your consent to store and process this data for this purpose at any time. You can find a corresponding link in every newsletter. In addition, you can also contact privacy@stevenhunt.net or unsubscribe from the newsletter directly on our website.

 

In principle, the data will not be passed on to third parties, unless this is necessary to fulfill the above-mentioned purposes. For example, this might be a parcel service provider, which also uses the personal data exclusively for the fulfillment of the above-mentioned purpose.

 

 

Dialogue After the Purchase of Our Products and Services

If we receive your personal data in connection with the sale of a product or service and you have not objected to this, we will process the data for the purpose of customer relations management and direct advertising by e-mail, postal mail or telephone for offers that are similar to the product or service you have already purchased. The legal basis for this is sec. 7 para. 3 UWG (German Act against Unfair Competition). You can object to this use of your contact data at any time and free of charge by sending a message to the contact option described or via a link provided for this purpose in the e-mail.

 

 

Contact by Steven Hunt & Associates

For the purpose of initiating dialogue with new contacts and expanding our network, we take the initiative to contact our primary contact persons. The channel through which this contact is established also depends on the contact data available to us (post, e-mail, or telephone). In doing so, we make use of publicly available data (e.g. in the legal notice).

 

The legal basis for this is our legitimate interest in developing business in accordance with art. 6 para. 1 lit. f) GDPR. Data subjects can reasonably expect their public personal data to be processed. We safeguard the interest of the target group, if possible, in not receiving uninteresting or unsuitable advertisements/offers by addressing them in a very targeted manner.

 

 

Administration

We process data in the context of administrative tasks as well as for the organization of our business (e.g. e-mail traffic, calendar maintenance), financial accounting and for compliance with legal obligations (e.g. reporting to authorities). In this connection, we process the same data that we process in the context of providing our contractual services, for the purpose of maintaining our business activities, performing our tasks and providing our services.

 

The legal basis for this is the necessity to fulfill the contract in accordance with art. 6 para. 1 lit. b) GDPR and our legal obligation in accordance with art. 6 para. 1 lit. c) GDPR.

 

 

Public Relations

For the purpose of expanding our business, we conduct public relations work. In doing so, we may process personal data such as names and photos.

 

The legal basis for this is the consent of the data subjects pursuant to art. 6 para. 1 lit. a) GDPR or – if the data has been published by the data subject himself/herself (art. 9 para. 2 lit. e) GDPR) – our legitimate interest pursuant to art. 6 para. 1 lit. f) GDPR.

 

 

Detailed Information About the Website

 

Collection of General Data and Information

When you access our website, the website provider automatically collects and stores information in so-called server log files, which your browser automatically transmits to us. These are: Browser type/browser version, operating system used, referrer URL (the page from which you accessed our website), host name of the accessing computer, time of the server request and IP address.

 

We cannot associate this data with specific persons. Furthermore, this data is also generated when accessing any other website on the internet. It is therefore not a special function of our website. Without this data it would not technically be possible to deliver and display the contents of the website in their entirety. To that extent, their collection is absolutely necessary. We also reserve the right to check the server log files retrospectively if we suspect an illegal use of our services.

 

Anonymous server log file data is stored separately from all personal data provided by a data subject.

 

 

Cookies

The web pages use cookies. This standard technology involves small text files that are stored on the device you use.

 

Steven Hunt & Associates uses cookies to make visiting the website more convenient or safer and to provide users with more user-friendly services, which would not be possible without the use of cookies. An example of this is a shopping cart cookie in our web shop. The web shop uses a cookie to remember the items that a customer has placed in the virtual shopping cart.

 

Most of the cookies we use are so-called “session cookies”. They are automatically deleted at the end of your visit. Other cookies are stored on your device until you delete them. These cookies enable us to recognize your browser on your next visit.

 

You are free to decide whether your browser allows cookies or not. Please note that the functionality of websites may be limited or even disabled if cookies are not allowed. Furthermore, cookies that have already been stored can be deleted at any time via an web browser or other software programs. This is possible in all common web browsers.

 

We do not pass this data to third parties or link it to other personal data without your consent.

 

 

YouTube Videos

Steven Hunt & Associates  has also embedded videos from YouTube on its website.

 

YouTube is operated by YouTube LLC, 901 Cherry Ave., San Bruno, CA 94066, USA. Further information can be found on the YouTube legal notice at https://www.youtube.com/t/impressum?hl=de&gl=DE.

 

In order for these videos to be called up and displayed on your browser, it is absolutely necessary to transmit the IP address. YouTube therefore receives your IP address.

 

Although we make every effort to use only third-party providers that only require the IP address in order to deliver content, we have no influence on whether the IP address is stored. Further privacy notices can be found in Google’s privacy policy at https://policies.google.com/privacy. There you can also configure your personal data protection settings yourself.

 

 

Newsletter and Mailing

Our e-mail newsletters are sent via the technical service provider, ActiveCampaign, LLC, 1 North Dearborn Street, 5th floor, Chicago, IL 60602, USA (https://www.activecampaign.com)

 

to whom we pass on the data you provided when registering for the newsletter. This disclosure is made in accordance with Art. 6 (1) point f GDPR and serves our legitimate interest in the use of an effective, secure and user-friendly newsletter system. Please note that your data is usually transferred to a ActiveCampaign server in the USA and stored there.

 

ActiveCampaign uses this information to send and statistically evaluate the newsletter on our behalf. For evaluation purposes, the e-mails sent contain so-called web beacons or tracking pixels, which represent single-pixel image files stored on our website. This allows us to determine whether a newsletter message has been opened and which links have been clicked on. In addition, technical information is recorded (e.g. time of retrieval, IP address, browser type and operating system). The data are raised exclusively in a pseudonymized format and are not linked with other personal data from you. A direct personal relationship is excluded. This data is used exclusively for statistical analysis of newsletter campaigns. The results of these analyses can be used to better adapt future newsletters to the interests of the recipients.

 

If you wish to object to the data analysis for statistical evaluation purposes, you must unsubscribe from the newsletter.

 

Furthermore, ActiveCampaign can use this data according to Art. 6 (1) point f GDPR even on the basis of its own legitimate interest in the demand-oriented design and optimization of the service as well as for market research purposes, for example to determine from which countries recipients come. However, ActiveCampaign does not use the data of our newsletter recipients to address those recipients or pass that data on to third parties.

 

The data protection regulations of MailChimp can be viewed at: https://www.activecampaign.com/legal/privacy-policy

 

 

Google Analytics

This website uses functions of the web analysis service Google Analytics. The provider is Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

 

Google Analytics uses so-called cookies. These are text files which are stored on your computer and which enable an analysis of your use of the website. The information generated by the cookie about your use of this website is usually transferred to a Google server in the USA and stored there.

 

The storage of Google Analytics cookies is based on art. 6 para. 1 lit. f GDPR. The website operator has a legitimate interest in the analysis of user behavior in order to optimize both its website and its advertising.

 

 

Browser Plugin

You can prevent the storage of cookies via your browser software settings; however, we would like to point out that, if cookies are blocked, you may not be able to use all functions of this website to their full extent. You can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) to Google and Google’s processing of this data by downloading and installing the browser plugin available under the following link: https://tools.google.com/dlpage/gaoptout?hl=de.

 

 

Objection to Data Collection

You can prevent Google Analytics from collecting your data by clicking on the following link. An opt-out cookie will then be set to prevent the collection of your information on future visits to this site: disable Google Analytics.

 

More information on how Google Analytics handles user data can be found in the Google privacy policy: https://support.google.com/analytics/answer/6004245?hl=de.

 

 

Commissioned Data Processing

We have concluded a contract with Google commissioning it to process data and fully implement the strict requirements of the German data protection authorities when using Google Analytics.

 

 

Storage Duration and Deletion

We comply with the principles of data avoidance and data economy. We therefore only store your personal data for as long as is necessary to fulfill the intended purposes or as required by the various storage periods prescribed by law. After the respective purpose has ceased to apply or once these periods have expired, the corresponding data is routinely blocked or deleted in accordance with the statutory provisions.

 

 

Changes to Our Privacy Policy

We reserve the right to adapt this privacy notice to ensure that it always complies with current legal requirements or to implement changes to our services within the privacy notice, such as the introduction of new services. The new privacy policy will then apply to your next visit.