Privacy Policy

Hoefer Inc. (“We”) are committed to protecting and respecting your privacy.

This policy (together with our terms of use and any other documents referred to on it) sets out the basis on which any Personal Data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your Personal Data and how we will treat it. Before using our website you are required to give specific consent to the processing of your Personal Data for the purposes set out under section “Uses made of the information” which you have done by checking the data processing consent box on our website.

Definitions

"Applicable Law" means (a) any law, statute, regulation, byelaw or subordinate legislation in force from time to time to which a Party is a subject and/or in any jurisdiction that the Master Agreement is performed in; (b) the common law and laws of equity as applicable to the Parties from time to time; (c) any binding court order, judgment or decree; (d) any applicable industry code, policy or standard; (e) any applicable direction, policy, rule or order that is binding on a party and that is made or given by any regulatory body having jurisdiction over a Party or any of that Party's assets, resources or business;

"Data Protection Laws" means any Applicable Law relating to the processing, privacy, and use of Personal Data, including (a) in the United Kingdom, (i) the Data Protection Act 1998 and the Privacy and Electronic Communications (EC Directive) Regulations 2003, SI 2003/2426, and any laws or regulations implementing Directive 95/46/EC (Data Protection Directive) or Directive 2002/58/EC (ePrivacy Directive); and/or (ii) the General Data Protection Regulation (EU) 2016/679 (GDPR), and/or any corresponding or equivalent national laws or regulations (Revised UK DP Law) (b) in member states of the European Union, the Data Protection Directive or the GDPR, once applicable, and the ePrivacy Directive, and all relevant member state laws or regulations giving effect to or corresponding with any of them; and (c) any judicial or administrative interpretation of any of the above, any guidance, guidelines, codes of practice, approved codes of conduct or approved certification mechanisms issued by any relevant Supervisory Authority;

"Data" means information which is stored electronically, on a computer, or in certain paper-based filing systems; "Personal Data" means any information relating to an identified or identifiable natural person ("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 and where referred to in this policy includes special categories of Personal Data.

Information we collect from you

We will collect and process the following Data about you:

• Information you give us. This is information about you that you give us by filling in forms on www.hoferinc.com (“our site”) or by corresponding with us by phone, email or otherwise. It includes information you provide when you register to use our site, subscribe to our service, participate in discussion boards or other social media functions on our site, and when you report a problem with our site. The information you give us may include your name, address, email address and phone number, financial and credit card information, personal description and photograph.
• Information we collect about you. With regard to each of your visits to our site we will automatically collect the following information:
o Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
o Information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number.
• Information we receive from other sources. This is information we receive about you if you use any of the other websites we operate or the other services we provide. In this case we will have informed you when we collected that data if we intend to share those data internally and combine it with data collected on this site. We will also have told you for what purpose we will share and combine your data. We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies). We will notify you when we receive information about you from them and the purposes for which we intend to use that information.

How we use cookies

A cookie is a small file which asks permission to be placed on your computer's hard drive. Once you agree, the file is added and the cookie helps analyze web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyze data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

List of cookies we collect

The table below lists the cookies we collect and what information they store.

CART
The association with your shopping cart
CATEGORY_INFO
Stores the category info on the page that allows to display pages more quickly
COMPARE
The items that you have in the Compare Products list
CURRENCY
Your preferred currency
CUSTOMER
An encrypted version of your customer id with the store
CUSTOMER_AUTH
An indicator if you are currently logged into the store
CUSTOMER_INFO
An encrypted version of the customer group you belong to
CUSTOMER_SEGMENT_IDS
Stores the Customer Segment ID
EXTERNAL_NO_CACHE
A flag, which indicates whether caching is disabled or not
FRONTEND
Your session ID on the server
_ga
Used to distinguish users
_gid
Used to distinguish users
_gat
Used to throttle request rate
_gac_
Contains campaign related information
GOOGLE __utma
A persistent cookie
GOOGLE __utmb
Tracks the exact arrival time
GOOGLE __utmc
Tracks the exact exit time
GOOGLE __utmt
Used to distinguish users and sessions
GOOGLE __utmv
Used to improve cookie targeting capabilities
GOOGLE __utmz
Monitors the HTTP Referrer
GUEST-VIEW
Allows guests to edit their orders
LAST_CATEGORY
The last category you visited
LAST_PRODUCT
The most recent product you have viewed
NEWMESSAGE
Indicates whether a new message has been received
NO_CACHE
Indicates whether it is allowed to use cache
PERSISTENT_SHOPPING_CART
A link to information about your cart and viewing history if you have asked the site
POLL
The ID of any polls you have recently voted in
POLLN
Information on what polls you have voted on RECENTLYCOMPARED
The items that you have recently compared
STF
Information on products you have emailed to friends
STORE
The store view or language you have selected
USER_ALLOWED_SAVE_COOKIE
Indicates whether a customer allowed to use cookies
VIEWED_PRODUCT_IDS
The products that you have recently viewed
WISHLIST
An encrypted list of products added to your Wishlist
WISHLIST_CNT
The number of items in your Wishlist

Uses made of the information

We use information held about you in the following ways:

1. Processing of an inquiry form completed by you;
2. Processing a request for a catalog or expressing an interest in one or more of our products;
3. Providing your information to our marketing department who may contact you by post, telephone or email to request feedback and comments on our services or to provide information to you which may be of interest to you;
4. Providing your information to our agents and service providers for the purposes set out in 3 above;
5. If applicable, processing your application for employment in which case we shall retain a copy of your CV in case of suitable future opportunities.

Information you give to us. We will use this information:

1. To carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
2. To provide you with information about other goods and services we offer that are similar to those that you have already purchased or inquired about;
3. To provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. If you are an existing customer, we will only contact you by electronic means (email or SMS) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, you will be able to withdraw your consent by contacting our Compliance Team;
4. To notify you about changes to our service; and
5. To ensure that content from our site is presented in the most effective manner for you and for your computer.

Information we collect about you. We will use this information:

1. To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
2. To improve our site to ensure that content is presented in the most effective manner for you and for your computer;
3. To allow you to participate in interactive features of our service, when you choose to do so;
4. As part of our efforts to keep our site safe and secure;
5. To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you; and
6. To make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
7. Information we receive from other sources. We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).

Disclosure of your information

You agree that we have the right to share your personal information with selected third parties including:

1. Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
2. Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we will provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in SW1). We may make use of the Personal Data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience;
3. Analytics and search engine providers that assist us in the improvement and optimization of our site;
4. Credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.

We will disclose your personal information to third parties:

1. In the event that we sell or buy any business or assets, in which case we will disclose your Personal Data to the prospective seller or buyer of such business or assets.
2. If Hoefer Inc. or substantially all of its assets are acquired by a third party, in which case Personal Data held by it about its customers will be one of the transferred assets.
3. If we are under a duty to disclose or share your Personal Data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of Hoefer Inc., our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Where we store your Personal Data

All information you provide to us is stored on secure servers. Any payment transactions will be encrypted. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

Your rights

You have the right to ask us not to process your Personal Data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any Personal Data to these websites.

Access to information

The Data Protection Laws give you the right to access information held about you. Your right of access can be exercised in accordance with the Data Protection Law. You also have the right to rectify Personal Data where it is no longer correct. If you wish to do so please contact us as set out below.

Right to Lodge a Complaint with Information Commissioner's Office ("ICO")

If you have any complaints about the way in which we process your Personal Data please do contact us, as set out below. Alternatively you have the right to lodge a formal complaint with the ICO.

Changes to our privacy policy

Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our privacy policy.

Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to our Compliance Team.

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