Privacy policy
Preamble
With the following privacy policy, we would like to inform you in general and for selected processing activities in detail about what types of your personal data (hereinafter also referred to as "data") we process, for what purposes and to what extent.
The 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 offer"). For processing activities that are not mentioned here, please refer to separate information.
The terms used are not gender-specific.
In data protection matters, we are governed exclusively by German or European law. Our contract language is German. Therefore, the German version of this data protection information is authoritative. The English version is for information purposes only.
Status: 19/08/2024
Table of contents
Part I - Basic information
02 Responsible party
03 Contact data protection officer
04 Overview of processing operations
07 Transmission of personal data
08 International data transfers
09 General information on data storage and erasure
Part II - Processing activities in detail
11 Performance of tasks in accordance with the articles of association or rules of procedure
12 Providers and services used in the course of business activities
13 Provision of the online services and web hosting
15 Blogs and publication media
16 Contact and enquiry management
17 Video conferences, online meetings, webinars and screen sharing
18 Newsletter and electronic notifications
19 Advertising communication by e-mail, post, fax or telephone
20 Sweepstakes and competitions
21 Non-scientific surveys and interviews
22 Web analysis, monitoring and optimisation
25 Presence in social networks (social media)
26 Plug-ins and embedded functions and content
27 Application procedure (workplace)
Part III - Special processing activities
28 Application for a study place (student application)
31 Administration of donations (twingle donation form)
Part IV - Update note and glossary
Part I - Basic information
02 Responsible party
Private Universität Witten/Herdecke gGmbH
Alfred-Herrhausen-Straße 50
D-58448 Witten
E-mail: public@uni-wh.de
Phone: +49 2302 926-0
Imprint: www.uni-wh.de/impressum/
03 Contact Data Protection Officer
Dipl.-Stat. Martin Rützler
Alfred-Herrhausen-Straße 50
D-58448 Witten
E-Mail: datenschutz@uni-wh.de
04 Overview of processing activities
The following overview summarises the types of data processed and the purposes of their processing for the processing activities described here and refers to the data subjects. (Definitions of the terms can be found at the end of the document)
Types of data processed in total
- Inventory data
- Payment data
- Location data
- contact data
- content data
- Contract data
- Usage data
- Meta, communication and process data
- Applicant data
- Image and/or video recordings
- Sound recordings
- Event data (Facebook)
- Protocol data.
- Member data
Categories of data subjects
- Service recipients and clients
- Interested parties
- Communication partners
- users
- Applicants
- Competition and contest participants
- members
- Business and contractual partners
- Participants
- Persons depicted
Purposes of the processing
- Provision of contractual services and fulfilment of contractual obligations
- Communication
- Security measures
- Direct marketing
- Reach measurement
- Tracking
- Office and organisational procedures
- remarketing
- Conversion measurement
- Click tracking
- Target group formation
- Organisational and administrative procedures
- Application procedures
- Organising competitions and contests
- feedback
- Surveys and questionnaires
- marketing
- Profiles with user-related information
- Provision of our online services and user-friendliness
- Information technology infrastructure
- Public relations and information purposes
- Sales promotion
- Business processes and business management procedures
05 Relevant legal bases
Relevant legal bases according to the GDPR:
Below you will find an overview of the legal bases of the GDPR on the basis of which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. Should more specific legal bases also apply in individual cases, we will inform you of these in the privacy policy.
- Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR) - The data subject has given their consent to the processing of their personal data for a specific purpose or several specific purposes.
- Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR) - Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
- Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR) - processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.
- Application procedure as a pre-contractual or contractual relationship (Art. 6 para. 1 sentence 1 lit. b) GDPR) - Insofar as special categories of personal data within the meaning of Art. 9 para. 1 GDPR are processed as part of the application procedure (e.g. health data, such as severely disabled status or ethnic origin) are requested from applicants so that the controller or the data subject can exercise their rights under labour law and social security and social protection law and fulfil their obligations in this regard, their processing is carried out in accordance with Art. 9 para. 2 lit. b. GDPR. GDPR, in the case of the protection of vital interests of applicants or other persons pursuant to Art. 9 para. 2 lit. c. GDPR or for the purposes of preventive healthcare or occupational medicine, for the assessment of the employee's fitness for work, for medical diagnosis, care or treatment in the health or social sector or for the management of systems and services in the health or social sector pursuant to Art. 9 para. 2 lit. h. GDPR. GDPR. In the case of communication of special categories of data based on voluntary consent, their processing is carried out on the basis of Art. 9 para. 2 lit. a. GDPR.
- Membership contract (articles of association) (Art. 6 para. 1 sentence 1 lit. b) GDPR).
National data protection regulations in Germany:
In addition to the data protection regulations of the GDPR, national data protection regulations apply in Germany. These include, in particular, the Act on the Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act - BDSG). In particular, the BDSG contains special regulations on the right to information, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes and transmission as well as automated decision-making in individual cases, including profiling. The data protection laws of the individual federal states may also apply.
06 General security measures
We take appropriate technical and organisational 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, in order to ensure a level of protection appropriate to the risk.
The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access, input, disclosure, safeguarding availability and separation of the data. Furthermore, we have established procedures that ensure the exercise of data subject rights, the deletion of data and responses to data threats. Furthermore, we already take the protection of personal data into account during the development or selection of hardware, software and procedures in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.
Shortening of the IP address: If IP addresses are processed by us or by the service providers and technologies used and the processing of a full IP address is not required, the IP address is truncated (also known as "IP masking"). In this process, the last two digits or the last part of the IP address after a dot are removed or replaced by placeholders. The shortening of the IP address is intended to prevent or significantly complicate the identification of a person based on their IP address.
Securing online connections using TLS/SSL encryption technology (HTTPS): To protect user data transmitted via our online services from unauthorised access, we use TLS/SSL encryption technology. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the Internet. These technologies encrypt the information transmitted between the website or app and the user's browser (or between two servers), protecting the data from unauthorised access. TLS, as the more advanced and secure version of SSL, ensures that all data transmissions meet the highest security standards. If a website is secured by an SSL/TLS certificate, this is signalled by the display of HTTPS in the URL. This serves as an indicator to users that their data is being transmitted securely and encrypted.
07 Transmission of personal data
As part of our processing of personal data, it may be transmitted to other bodies, institutions, companies, legally independent organisational units or persons or disclosed to them. The recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and, in particular, conclude corresponding contracts or agreements with the recipients of your data that serve to protect your data.
Data transfer within the organisation: If data is transferred for administrative purposes, it is based on our legitimate business and commercial interests or is carried out if it is necessary to fulfil our contractual obligations or if the consent of the data subjects or legal permission has been obtained.
08 International data transfers
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 the processing takes place in the context of the use of third-party services or the disclosure or transfer of data to other persons, bodies or companies, this only takes place in accordance with the legal requirements. If the level of data protection in the third country has been recognised by means of an adequacy decision (Art. 45 GDPR), this serves as the basis for the data transfer. Otherwise, data will only be transferred if the level of data protection is otherwise ensured, in particular through standard contractual clauses (Art. 46 para. 2 lit. c) GDPR), express consent or in the case of contractual or legally required transfer (Art. 49 para. 1 GDPR). In addition, we will inform you of the basis for third country transfers with the individual providers from the third country, whereby the adequacy decisions take precedence. Information on third country transfers and existing adequacy decisions can be found in the information provided by the EU Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en?prefLang=de
EU-US Trans-Atlantic Data Privacy Framework: As part of the so-called "Data Privacy Framework" (DPF), the EU Commission has also recognised the level of data protection for certain companies from the USA as secure as part of the adequacy decision of 10.07.2023. The list of certified companies and further information on the DPF can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/. As part of the data protection information, we will inform you which service providers we use are certified under the Data Privacy Framework.
09 General information on data storage and erasure
We delete personal data that we process in accordance with the statutory provisions as soon as the underlying consents are revoked or there is no further legal basis for the processing. This applies to cases in which the original purpose of processing no longer applies or the data is no longer required. There are exceptions to this rule if legal obligations or special interests require longer storage or archiving of the data.
In particular, data that must be stored for commercial or tax law reasons or whose storage is necessary for legal prosecution or to protect the rights of other natural or legal persons must be archived accordingly.
Our data protection information contains additional information on the retention and deletion of data that applies specifically to certain processing operations.
If there is more than one indication of the retention period or deletion period for a date, the longest period is always decisive.
If a period does not expressly begin on a specific date and is at least one year, it automatically starts at the end of the calendar year in which the event triggering the period occurred. In the case of ongoing contractual relationships in the context of which data is stored, the event triggering the deadline is the date on which the cancellation or other termination of the legal relationship takes effect.
We only process data that is no longer stored for the originally intended purpose, but due to legal requirements or other reasons, for the reasons that justify its storage.
Further information on processing processes, procedures and services:
Retention and deletion of data:
The following general periods apply to retention and archiving under German law:
- 10 years - Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheet as well as the work instructions and other organisational documents required for their understanding, accounting vouchers and invoices (§ 147 para. 3 in conjunction with para. 1 no. 1, 4 and 4a AO, § 14b para. 1 UStG, § 257 para. 1 no. 1 and 4, para. 4 HGB).
- 6 years - Other business documents: commercial or business letters received, reproductions of commercial or business letters sent, other documents, insofar as they are of significance for taxation, e.g. Hourly wage slips, company accounting sheets, calculation documents, but also payroll accounting documents, insofar as they are not already accounting documents (§ 147 para. 3 in conjunction with para. 1 no. 2, 3, 5 AO, § 257 para. 1 no. 2 and 3, para. 4 HGB).
- 3 years - Data required to consider potential warranty and compensation claims or similar contractual claims and rights and to process related enquiries based on previous business experience and standard industry practices are stored for the duration of the regular statutory limitation period of three years (Sections 195, 199 BGB).
10 Rights of the data subjects
Rights of data subjects under the GDPR: As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Art. 15 to 21 GDPR:
- Right to object: You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on point (e) or (f) of Article 6(1) GDPR, including profiling based on those provisions. If the personal data concerning you are processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.
- Right to withdraw consent: You have the right to withdraw any consent you have given at any time.
- Right to information: You have the right to request confirmation as to whether data concerning you is being processed and the right to 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 to request the completion of data concerning you or the rectification of inaccurate data concerning you in accordance with the legal requirements.
- Right to erasure and restriction of processing: In accordance with the legal requirements, you have the right to demand that data concerning you be erased immediately or, alternatively, in accordance with the legal requirements, you have the right to demand that the processing of the data be restricted.
- Right to data portability: You have the right to receive the data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format in accordance with the legal requirements or to request its transmission to another controller.
- Complaint to the supervisory authority: In accordance with the statutory provisions and without prejudice to any other administrative or judicial remedy, you also have the right to lodge a complaint with a data protection supervisory authority, in particular a supervisory authority in the Member State in which you are habitually resident, the supervisory authority of your place of work or the place of the alleged infringement, if you consider that the processing of personal data relating to you infringes the GDPR.
Supervisory authority responsible for UW/H:
State Commissioner for Data Protection and Freedom of Information of the State of North Rhine-Westphalia(https://www.ldi.nrw.de/)
Part II - Processing activities in detail
11 Performance of tasks in accordance with the statutes or rules of procedure
We process the data of university members, i.e. our members, supporters, interested parties, business partners or other persons (collectively referred to as "data subjects") if we have a membership or other business relationship with them and fulfil our tasks and are recipients of benefits and donations. Otherwise, we process the data of data subjects on the basis of our legitimate interests, e.g. in the case of administrative tasks or public relations work.
The data processed in this context, the type, scope and purpose and the necessity of its processing are determined by the underlying membership or contractual relationship, from which the necessity of any data information also arises (we also refer to necessary data).
We delete data that is no longer required for the fulfilment of our statutory and business purposes. This is determined according to the respective tasks and contractual relationships. We retain the data for as long as it may be relevant for business transactions and with regard to any warranty or liability obligations based on our legitimate interests in their regulation. The necessity of retaining the data is regularly reviewed; otherwise, the statutory retention obligations apply.
- Processed data types:
- Inventory data (e.g. full name, residential address, contact information, etc.);
- Contact data (e.g. postal and email addresses or telephone numbers);
- Contract data (e.g. subject matter of the contract, term).
- Member data (e.g. personal data such as name, age, gender, contact details (email address, telephone number), participation in events, etc.).
- Data subjects:
- Members.
- Purposes of the processing:
- Communication.
- Organisational and administrative procedures.
- Storage and erasure:
- Deletion in accordance with the information in the section
"General information on data storage and deletion".
- Deletion in accordance with the information in the section
- Legal bases:
- Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- Membership contract (articles of association) (Art. 6 para. 1 sentence 1 lit. b) GDPR).
Further information on processing processes, procedures and services:
- National data protection regulations in Germany: In addition to the data protection regulations of the GDPR, national data protection regulations apply in Germany. These include, in particular, the Act on the Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act - BDSG). In particular, the BDSG contains special regulations on the right to information, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes and transmission as well as automated decision-making in individual cases, including profiling. Furthermore, state data protection laws of the individual federal states may apply.
12 Providers and services used as part of our business activities
As part of our business activities, we use additional services, platforms, interfaces or plug-ins from third-party providers ("services" for short) in compliance with legal requirements. Their use is based on our interests in the proper, lawful and economic management of our business operations and our internal organisation.
- Types of data processed:
- Inventory data (e.g. full name, residential address, contact information, etc.);
- Payment data (e.g. bank details, invoices, payment history);
- Contact data (e.g. postal and e-mail addresses or telephone numbers);
- Content data (e.g. textual or visual messages and contributions as well as the information relating to them, such as information on authorship or time of creation).
- Contract data (e.g. subject matter of the contract, term, contract category).
- Data subjects:
- Service recipients and clients;
- Interested parties.
- Business and contractual partners.
- Purposes of processing:
- Provision of contractual services and fulfilment of contractual obligations;
- Office and organisational procedures.
- Business processes and business management procedures.
- Storage and erasure:
- Deletion in accordance with the information in the section
"General information on data storage and deletion".
- Deletion in accordance with the information in the section
- Legal bases:
- Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- If applicable, order processing (Art. 28 GDPR).
Further information on processing processes, procedures and services:
- Softgarden applicant management software: Services in connection with employee acquisition/recruitment (search for employees, communication, application procedures, contract negotiations);
Service provider: softgarden e-recruiting GmbH, Tauentzienstraße 14, 10789 Berlin, Germany;
Legal basis: The processing of applicant data for UW/H takes place within the framework of order processing in accordance with Art. 28 GDPR). Any further processing for the purposes of Softgarden e-recruiting GmbH is carried out either on the basis of legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR) or your consent (Art. 6 para. 1 sentence 1 lit. a) GDPR);
Website:https://www.softgarden.de;
Privacy Policy: https://www.softgarden.de/unternehmen/datenschutz-webseite/;
Basis for third country transfers: Standard Contractual Clauses (conclusion with subcontractors with regard to the storage of data in the USA).
Deletion of data: The application documents in the applicant pool will be processed solely in the context of future job advertisements and the search for employees and will be destroyed at the latest after the specified period has expired. Applicants are informed that their consent to inclusion in the applicant pool is voluntary, has no influence on the current application process and that they can revoke this consent at any time for the future.
13 Provision of the online services and web hosting
We process users' data in order to provide them with our online services. For this purpose, we process the user's IP address, which is necessary to transmit the content and functions of our online services to the user's browser or end device.
- Processed data types:
- Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions);
- Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
- Log data (e.g. log files relating to logins or the retrieval of data or access times).
- Data subjects:
- Users (e.g. website visitors, users of online services).
- Purposes of the processing:
- Provision of our online services and user-friendliness;
- Information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)).
- Security measures.
- Storage and deletion:
- Deletion in accordance with the information in the section
"General information on data storage and deletion".
- Deletion in accordance with the information in the section
- Legal bases:
- Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing processes, procedures and services:
- Provision of online offer on own/ dedicated server hardware: For the provision of our online offer, we use server hardware operated by us as well as the associated storage space, computing capacity and software;
Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). - Collection of access data and log files: Access to our online offering is recorded in the form of so-called "server log files". The server log files may include the address and name of the websites and files accessed, the date and time of access, the amount of data transferred, notification of successful access, browser type and version, the user's operating system, 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 (especially in the event of abusive attacks, so-called DDoS attacks), and to ensure the utilisation of the servers and their stability;
Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymised. Data whose further storage is required for evidentiary purposes is excluded from erasure until the respective incident has been finally clarified.
14 Use of cookies
Cookies are small text files or other storage devices that store information on end devices and read it from them. For example, to store the log-in status in a user account, the contents of a shopping basket in an e-shop, the content accessed or the functions used in an online offering. Cookies can also be used for various purposes, for example to ensure the functionality, security and convenience of online services and to create analyses of visitor flows.
Information on consent: We use cookies in accordance with the statutory provisions. We therefore obtain prior consent from users, unless this is not required by law. In particular, consent is not required if the storage and reading of information, including cookies, is absolutely necessary in order to provide users with a digital service they have expressly requested (i.e. our online offering). The revocable consent is clearly communicated to you and contains the information on the respective use of cookies.
Information on legal bases under data protection law: The legal basis under data protection law on which we process users' personal data using cookies depends on whether we ask for their consent. If the users accept, the legal basis for the utilisation of their data is the declared consent. Otherwise, the data processed using cookies is processed on the basis of our legitimate interests (e.g. in the commercial operation of our online offering and the improvement of its usability) or, if this is done in the context of the fulfilment of our contractual obligations, if the use of cookies is necessary to fulfil our contractual obligations. We will explain the purposes for which we use cookies in the course of this privacy policy or as part of our consent and processing procedures.
Storage duration: With regard to the storage duration, a distinction is made between the following types of cookies
- Temporary cookies (also: session or session cookies): Temporary cookies are deleted at the latest after a user has left an online offering and closed their end device (e.g. browser or mobile application).
- Permanent cookies: Permanent cookies remain stored even after the end device is closed. For example, the log-in status can be saved and favourite content can be displayed directly when the user visits a website again. The user data collected with the help of cookies can also be used to measure reach. If we do not provide users with explicit information on the type and storage duration of cookies (e.g. when obtaining consent), users should assume that they are permanent and that the storage duration can be up to two years.
General information on revocation and objection (opt-out): Users can revoke the consent they have given at any time and also object to the processing in accordance with the legal requirements, also by means of the privacy settings of their browser.
- Processed data types:
- Meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, persons involved).
- Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions).
- Data subjects:
- Users (e.g. website visitors, users of online services).
- Purposes of the processing:
- Provision of our online services and user-friendliness.
- Legal bases:
- Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
Further information on processing processes, procedures and services:
- Processing of cookie data on the basis of consent: We use a consent management solution in which user consent is obtained for the use of cookies or for the procedures and providers mentioned in the consent management solution. This procedure is used to obtain, log, manage and revoke consent, in particular with regard to the use of cookies and comparable technologies that are used to store, read and process information on users' end devices. As part of this procedure, user consent is obtained for the use of cookies and the associated processing of information, including the specific processing and providers mentioned in the consent management procedure. Users also have the option of managing and revoking their consent. The declarations of consent are stored in order to avoid repeated requests and to be able to provide proof of consent in accordance with legal requirements. The storage takes place on the server side and/or in a cookie (so-called opt-in cookie) or by means of comparable technologies in order to be able to assign the consent to a specific user or their device. If no specific information on the providers of consent management services is available, the following general information applies: Consent is stored for up to two years. A pseudonymous user identifier is created, which is stored together with the time of consent, information on the scope of consent (e.g. relevant categories of cookies and/or service providers) and information on the browser, the system and the end device used;
Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). - Cookie opt-out: In the footer of our website you will find a link that you can use to change your cookie settings and revoke your consent;
Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). - consentmanager: Consent management: Procedure for obtaining, logging, managing and revoking consent, in particular for the use of cookies and similar technologies for storing, reading and processing information on users' end devices and their processing;
Service provider: Jaohawi AB, Håltegelvägen 1b, 72348 Västerås, Sweden;
Website: https://www.consentmanager.de/;
Privacy Policy: https://www.consentmanager.net/;
Data processing agreement: https://www.consentmanager.net/tac.php.
Further information: The following data is stored on the service provider's servers in the EU Identification number, (for the user, his browser, operating system and the terminal device used), IP address, date and time, country, language, type, scope and purpose of the consent, cookie settings of the browser, website on which the consent was given, technical information on the browser and operating system.
15 Blogs and publication media
We use blogs or comparable means of online communication and publication (hereinafter "publication medium"). User data is only processed for the purposes of the publication medium to the extent necessary for its presentation and communication between authors and readers or for security reasons. For further information, please refer to the information on the processing of visitor data for our publication medium in this data protection notice.
- Processed data types:
- Inventory data (e.g. full name, residential address, contact information, etc.);
- Contact data (e.g. postal and email addresses or telephone numbers);
- Content data (e.g. textual or visual messages and contributions as well as the information relating to them, such as information on authorship or time of creation);
- Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
- Data subjects:
- Users (e.g. website visitors, users of online services).
- Purposes of the processing:
- Feedback (e.g. collecting feedback via online form);
- Provision of our online services and user-friendliness;
- Security measures. Organisational and administrative procedures.
- Storage and deletion:
- Deletion in accordance with the information in the section
"General information on data storage and deletion".
- Deletion in accordance with the information in the section
- Legal bases:
- Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing processes, procedures and services:
- Comments and posts: If users leave comments or other posts, their IP addresses may be stored on the basis of our legitimate interests. This is done for our security in case someone leaves illegal content in comments and posts (insults, prohibited political propaganda, etc.). In this case, we ourselves may be prosecuted for the comment or post and are therefore interested in the identity of the author.
Furthermore, we reserve the right to process user data for the purpose of spam detection on the basis of our legitimate interests.
On the same legal basis, we reserve the right to store the IP addresses of users for the duration of surveys and to use necessary cookies to avoid multiple votes.
The personal information provided in the context of comments and contributions, any contact and website information as well as the content information will be stored permanently by us until the user objects;
Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
16 Contact and enquiry management
When contacting us (e.g. by post, contact form, email, telephone or via social media) and as part of existing user and business relationships, the details of the enquiring persons are processed insofar as this is necessary to answer the contact enquiries and any measures requested.
- Processed data types:
- Inventory data (e.g. full name, residential address, contact information, etc.);
- Contact data (e.g. postal and email addresses or telephone numbers);
- Content data (e.g. textual or visual messages and contributions as well as the information relating to them, such as information on authorship or time of creation);
- Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions).
- Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
- Data subjects:
- Communication partners.
- Purposes of processing:
- Communication; organisational and administrative procedures; feedback (e.g. collecting feedback via online form).
- Provision of our online services and user-friendliness.
- Storage and deletion:
- Deletion in accordance with the information in the section
"General information on data storage and deletion".
- Deletion in accordance with the information in the section
- Legal bases:
- Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
Further information on processing processes, procedures and services:
- Contact form: When contacting us via our contact form, by email or other communication channels, we process the personal data transmitted to us to answer and process the respective request. This generally includes details such as name, contact information and any other information that is provided to us and is required for appropriate processing. We use this data exclusively for the stated purpose of establishing contact and communication;
Legal bases: Contract fulfilment and pre-contractual enquiries (Art. 6 Para. 1 S. 1 lit. b) GDPR), Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR).
17 Video conferences, online meetings, webinars and screen sharing
We use platforms and applications of other providers (hereinafter referred to as "conference platforms") for the purpose of conducting video and audio conferences, webinars and other types of video and audio meetings (hereinafter collectively referred to as "conference"). When selecting the conference platforms and their services, we observe the legal requirements.
Data processed by conference platforms: In the context of participation in a conference, the conference platforms process the personal data of the participants listed below. The scope of the processing depends on which data is required in the context of a specific conference (e.g. specification of access data or clear names) and which optional information is provided by the participants. In addition to processing for the purpose of holding the conference, the conference platforms may also process participants' data for security purposes or service optimisation. The processed data includes personal data (first name, surname), contact information (e-mail address, telephone number), access data (access codes or passwords), profile pictures, information on professional position/function, the IP address of the Internet access, information on the participants' end devices, their operating system, the browser and its technical and language settings, information on the content of the communication processes, i.e. entries in chats and audio recordings. The content of communications, i.e. entries in chats and audio and video data, as well as the use of other available functions (e.g. surveys). The content of communications is encrypted to the extent technically provided by the conference providers. If the participants are registered as users with the conference platforms, further data may be processed in accordance with the agreement with the respective conference provider.
Logging and recordings: If text entries, participation results (e.g. from surveys) and video or audio recordings are logged, this will be transparently communicated to participants in advance and they will be asked for consent where necessary.
Data protection measures for participants: Please note the details of how the conference platforms process your data in their data protection notices and select the security and data protection settings that are best for you in the conference platform settings. Please also ensure data and privacy protection in the background of your recording for the duration of a video conference (e.g. by informing roommates, locking doors and using the function to make the background unrecognisable if technically possible). Links to the conference rooms and access data may not be passed on to unauthorised third parties.
Notes on legal bases: If, in addition to the conference platforms, we also process users' data and ask users for their consent to use the conference platforms or certain functions (e.g. consent to the recording of conferences), the legal basis for processing is this consent. Furthermore, our processing may be necessary to fulfil our contractual obligations (e.g. in participant lists, in the case of processing the results of discussions, etc.). Otherwise, user data is processed on the basis of our legitimate interests in efficient and secure communication with our communication partners.
- Processed data types:
- Inventory data (e.g. full name, residential address, contact information, etc.);
- Contact data (e.g. postal and email addresses or telephone numbers);
- Content data (e.g. textual or visual messages and contributions as well as the information relating to them, such as information on authorship or time of creation);
- Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions);
- Image and/or video recordings (e.g. photographs or video recordings of a person);
- Sound recordings.
- Log data (e.g. log files relating to logins or the retrieval of data or access times).
- Data subjects:
- Communication partners;
- Users (e.g. website visitors, users of online services).
- Depicted persons.
- Purposes of the processing:
- Provision of contractual services and fulfilment of contractual obligations;
- Communication.
- Office and organisational procedures.
- Storage and erasure:
- Deletion in accordance with the information in the section
"General information on data storage and deletion".
- Deletion in accordance with the information in the section
- Legal bases:
- Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing processes, procedures and services:
- Zoom: Conference and communication software;
Service provider: Zoom Video Communications, Inc, 55 Almaden Blvd, Suite 600, San Jose, CA 95113, USA;
Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR);
Website: https://zoom.us;
Privacy Policy: https://explore.zoom.us/docs/de-de/privacy-and-legal.html;
Data processing agreement: https://zoom.us/docs/de-de/privacy-and-legal.html (referred to as Global DPA).
Basis for third country transfers: Data Privacy Framework (DPF).
18 Newsletter and electronic notifications
We send newsletters, emails and other electronic notifications (hereinafter referred to as "newsletters") exclusively with the consent of the recipient or on the basis of a legal basis. If the contents of the newsletter are mentioned in the context of a registration for the newsletter, these contents are decisive for the consent of the users. To subscribe to our newsletter, it is normally sufficient to provide your e-mail address. However, in order to be able to offer you a personalised service, we may ask you to provide your name so that we can address you personally in the newsletter or to provide further information if this is necessary for the purpose of the newsletter.
Deletion and restriction of processing: We may store the unsubscribed e-mail addresses for up to three years on the basis of our legitimate interests before deleting them in order to be able to prove that consent was previously given. The processing of this data is limited to the purpose of a potential defence against claims. An individual request for erasure is possible at any time, provided that the former existence of consent is confirmed at the same time. In the event of obligations to permanently observe objections, we reserve the right to store the e-mail address in a block list solely for this purpose.
The registration process is logged on the basis of our legitimate interests for the purpose of proving that it has been carried out properly. If we commission a service provider to send e-mails, this is done on the basis of our legitimate interests in an efficient and secure dispatch system.
Content: Information about us, our services, promotions and offers.
- Processed data types:
- Inventory data (e.g. full name, residential address, contact information, etc.);
- Contact data (e.g. postal and email addresses or telephone numbers);
- Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved);
- usage data (e.g. page views and dwell time, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions).
- Content data (e.g. textual or visual messages and contributions as well as the information relating to them, such as information on authorship or time of creation).
- Data subjects:
- Communication partners;
- Users (e.g. website visitors, users of online services).
- Business and contractual partners.
- Purposes of the processing:
- Direct marketing (e.g. by email or post);
- Communication.
- Organisational and administrative procedures.
- Storage and erasure:
- Deletion in accordance with the information in the section
"General information on data storage and deletion".
- Deletion in accordance with the information in the section
- Legal basis:
- Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
- Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- Possibility of objection (opt-out):
- You can cancel the receipt of our newsletter at any time, i.e. revoke your consent or object to further receipt. You will find a link to unsubscribe from the newsletter either at the end of each newsletter or you can use one of the contact options listed above, preferably email.
Further information on processing operations, procedures and services:
- Measurement of opening and click rates: the newsletters contain a so-called "web beacon", i.e. a pixel-sized file that is retrieved from our server or its server if we use a dispatch service provider, when the newsletter is opened. As part of this retrieval, technical information, such as details of the browser and your system, as well as your IP address and the time of retrieval are initially collected. This information is used for the technical improvement of our newsletter based on the technical data or the target groups and their reading behaviour based on their retrieval locations (which can be determined using the IP address) or the access times. This analysis also includes determining whether and when the newsletters are opened and which links are clicked on. The information is assigned to the individual newsletter recipients and stored in their profiles until it is deleted. The analyses are used to recognise the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users. The measurement of opening and click rates as well as the storage of the measurement results in the user profiles and their further processing are carried out on the basis of user consent. Unfortunately, it is not possible to revoke the performance measurement separately; in this case, the entire newsletter subscription must be cancelled or objected to. In this case, the stored profile information will be deleted;
Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
19 Advertising communication via email, post, fax or telephone
We process personal data for the purposes of advertising communication, which may take place via various channels, such as e-mail, telephone, post or fax, in accordance with legal requirements.
Recipients have the right to revoke their consent at any time or to object to advertising communication at any time.
After revocation or objection, we store the data required to prove the previous authorisation for contacting or sending for up to three years after the end of the year of revocation or objection on the basis of our legitimate interests. The processing of this data is limited to the purpose of a possible defence against claims. On the basis of the legitimate interest in permanently observing the revocation or objection of the user, we also store the data required to avoid renewed contact (e.g. depending on the communication channel, the e-mail address, telephone number, name).
- Processed data types:
- Inventory data (e.g. full name, residential address, contact information, etc.);
- Contact data (e.g. postal and email addresses or telephone numbers).
- Content data (e.g. textual or pictorial messages and contributions as well as the information relating to them, such as information on authorship or time of creation).
- Data subjects:
- Communication partners.
- Purposes of the processing:
- Direct marketing (e.g. by email or post);
- Marketing.
- Sales promotion.
- Storage and erasure:
- Deletion in accordance with the information in the section
"General information on data storage and deletion".
- Deletion in accordance with the information in the section
- Legal basis:
- Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
- Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
20 Sweepstakes and competitions
We process personal data of participants in competitions and contests only in compliance with the relevant data protection regulations, insofar as the processing is contractually required for the provision, execution and handling of the competition, the participants have consented to the processing or the processing serves our legitimate interests (e.g. in the security of the competition or the protection of our interests against misuse through the possible collection of IP addresses when submitting competition entries).
If participants' entries are published as part of the competitions (e.g. as part of a vote or presentation of the competition entries or the winners or reporting on the competition), we would like to point out that the names of the participants may also be published in this context. Participants can object to this at any time.
If the competition takes place within an online platform or a social network (e.g. Facebook or Instagram, hereinafter referred to as "online platform"), the terms of use and data protection provisions of the respective platforms also apply. In these cases, we would like to point out that we are responsible for the information provided by the participants as part of the competition and that enquiries regarding the competition should be directed to us.
Participants' data will be deleted as soon as the competition or contest has ended and the data is no longer required to inform the winners or because no further queries about the competition are to be expected. In principle, participants' data will be deleted no later than 6 months after the end of the competition. Winners' data may be retained for longer, e.g. to answer queries about the prizes or to fulfil the prize; in this case, the retention period depends on the type of prize and is up to three years for items or services, e.g. to be able to process warranty claims. Furthermore, participants' data may be stored for longer, e.g. in the form of reporting on the competition in online and offline media.
If data is also collected for other purposes as part of the competition, its processing and the retention period are based on the data protection information for this use (e.g. in the case of registration for the newsletter as part of a competition).
- Processed data types:
- Inventory data (e.g. full name, residential address, contact information, etc.);
- Contact data (e.g. postal and email addresses or telephone numbers).
- Content data (e.g. textual or pictorial messages and contributions as well as the information relating to them, such as information on authorship or time of creation).
- Data subjects:
- Competition and contest participants.
- Purposes of processing:
- Realisation of competitions and contests.
- Storage and deletion:
- Deletion in accordance with the information in the section
"General information on data storage and deletion".
- Deletion in accordance with the information in the section
- Legal bases:
- Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
- Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
21 Non-scientific surveys and interviews
We conduct non-scientific surveys and interviews in order to collect information for the communicated purpose of the survey or interview. The surveys and interviews (hereinafter referred to as "surveys") we conduct are analysed anonymously. Personal data is only processed to the extent that this is necessary for the provision and technical implementation of the surveys (e.g. processing of the IP address to display the survey in the user's browser or to enable the survey to be resumed with the help of a cookie). For scientific surveys and interviews, the processing characteristics specified separately for the specific research project apply in each case.
- Processed data types:
- Inventory data (e.g. full name, home address, contact information, etc.);
- Contact data (e.g. postal and email addresses or telephone numbers);
- Content data (e.g. textual or visual messages and contributions as well as the information relating to them, such as information on authorship or time of creation).
- Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions).
- Affected persons:
- Participants.
- Purposes of the processing:
- Feedback (e.g. collecting feedback via online form).
- Surveys and questionnaires (e.g. surveys with input options, multiple choice questions).
- Storage and deletion:
- Deletion in accordance with the information in the section
"General information on data storage and deletion".
- Deletion in accordance with the information in the section
- Legal basis:
- Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
22 Web analysis, monitoring and optimisation
Web analysis (also referred to as "reach measurement") is used to evaluate the flow of visitors to our online offering and may include behaviour, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can, for example, recognise at what time our online offering or its functions or content are most frequently used or invite visitors to reuse them. It also enables us to understand which areas require optimisation.
In addition to web analysis, we may also use test procedures, for example to test and optimise different versions of our online offering or its components.
Unless otherwise stated below, profiles, i.e. data summarised for a usage process, may be created for these purposes and information may be stored in a browser or end device and then read out. The information collected includes, in particular, websites visited and the elements used there as well as technical information such as the browser used, the computer system used and information on usage times. If users have consented to the collection of their location data from us or from the providers of the services we use, location data may also be processed.
In addition, the IP addresses of users are stored. However, we use an IP masking procedure (i.e. pseudonymisation by shortening the IP address) to protect users. In general, no clear user data (such as email addresses or names) is stored in the context of web analysis, A/B testing and optimisation, but pseudonyms. This means that neither we nor the providers of the software used know the actual identity of the users, but only the information stored in their profiles for the purpose of the respective process.
Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is consent. Otherwise, user data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.
- Processed data types:
- Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions).
- Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
- Data subjects:
- Users (e.g. website visitors, users of online services).
- Purposes of the processing:
- Reach measurement (e.g. access statistics, recognising returning visitors).
- Profiles with user-related information (creation of user profiles).
- Storage and deletion:
- Deletion in accordance with the information in the section
"General information on data storage and deletion". - Storage of cookies for up to 2 years (Unless otherwise stated, cookies and similar storage methods may be stored on users' devices for a period of two years).
- Deletion in accordance with the information in the section
- Security measures:
- IP masking (pseudonymisation of the IP address).
- Legal basis:
- Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
- Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing processes, procedures and services:
- Notes on consent recipients: The consent given by users in the context of a consent dialogue (also known as "cookie opt-in/consent", "cookie banner", etc.) fulfils several purposes. On the one hand, it serves to fulfil our obligation to obtain consent to the storage and reading of information on and from the user's end device (in accordance with ePrivacy guidelines). Secondly, it covers the processing of users' personal data in accordance with data protection regulations. In addition, this consent also applies to Google, as the company is obliged under the Digital Markets Act to obtain consent for personalised services. We therefore share the status of the consents given by users with Google. Our consent management software informs Google whether consent has been granted or not. The aim is to ensure that the consents given or not given by users are taken into account when using Google Analytics and when integrating functions and external services. For example, user consents and their revocation in the context of Google Analytics and other Google services in our online offering can be adjusted dynamically and depending on the user selection;
Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland;
Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR);
Website: https://support.google.com/analytics/answer/9976101?hl=de.
Privacy Policy: https://policies.google.com/privacy. - Google Tag Manager: We use Google Tag Manager, a software from Google that enables us to manage so-called website tags centrally via a user interface. Tags are small code elements on our website that are used to record and analyse visitor activity. This technology helps us to improve our website and the content offered on it. Google Tag Manager itself does not create any user profiles, does not store any cookies with user profiles and does not carry out any independent analyses. Its function is limited to simplifying the integration and management of tools and services that we use on our website and making them more efficient. Nevertheless, when using the Google Tag Manager, the IP address of the user is transmitted to Google, which is necessary for technical reasons in order to implement the services we use. Cookies may also be set in the process. However, this data processing only takes place if services are integrated via the Tag Manager. For more detailed information on these services and their data processing, please refer to the further sections of this privacy policy;
Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland;
Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR);
Website: https://marketingplatform.google.com;
Privacy Policy: https://policies.google.com/privacy;
Data processing agreement: https://business.safety.google/adsprocessorterms.
Basis for third country transfers: Data Privacy Framework (DPF). - Matomo: Matomo is software that is used for the purposes of web analysis and reach measurement. When Matomo is used, cookies are generated and stored on the user's end device. The user data collected when using Matomo is only processed by us and is not shared with third parties. The cookies are stored for a maximum period of 13 months: https: //matomo.org/faq/general/faq_146/;
Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
Deletion of data: The cookies are stored for a maximum period of 13 months.
23 Online marketing
We process personal data for the purpose of online marketing, which may include in particular the marketing of advertising space or the presentation of advertising and other content (collectively referred to as "content") based on the potential interests of users and the measurement of its effectiveness.
For these purposes, so-called user profiles are created and stored in a file (the so-called "cookie") or similar procedures are used, by means of which the information about the user relevant to the presentation of the aforementioned content is stored. This may include, for example, content viewed, websites visited, online networks used, but also communication partners and technical information, such as the browser used, the computer system used and information on usage times and functions used. If users have consented to the collection of their location data, this can also be processed.
The IP addresses of users are also stored. However, we use available IP masking procedures (i.e. pseudonymisation by shortening the IP address) for user protection. In general, no clear user data (such as e-mail addresses or names) is stored as part of the online marketing process, but pseudonyms. This means that neither we nor the providers of the online marketing procedures know the actual identity of the users, but only the information stored in their profiles.
The statements in the profiles are generally stored in cookies or by means of similar procedures. These cookies can generally also be read later on other websites that use the same online marketing process, analysed for the purpose of displaying content, supplemented with further data and stored on the server of the online marketing process provider.
In exceptional cases, it is possible to assign clear data to the profiles, primarily if the users are, for example, members of a social network whose online marketing process we use and the network links the user profiles with the aforementioned data. Please note that users can make additional agreements with the providers, for example by giving their consent during registration.
In principle, we only receive access to summarised information about the success of our advertisements. However, as part of so-called conversion measurements, we can check which of our online marketing processes have led to a so-called conversion, i.e., for example, to the conclusion of a contract with us. The conversion measurement is used solely to analyse the success of our marketing measures.
Unless otherwise stated, we ask you to assume that the cookies used are stored for a period of two years.
Notes on legal bases:
If we ask users for their consent to the use of third-party providers, the legal basis for data processing is consent. Otherwise, user data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.
Information on cancellation and objection:
We refer to the data protection notices of the respective providers and the objection options specified for the providers (so-called "opt-out"). If no explicit opt-out option has been specified, you have the option of switching off cookies in your browser settings. However, this may restrict the functions of our online offering. We therefore recommend the following additional opt-out options, which are summarised for the respective areas:
a) Europe: https: //www.youronlinechoices.eu.
b) Canada: https: //www.youradchoices.ca/choices.
c) USA: https: //www.aboutads.info/choices.
d) Cross-territory: https://optout.aboutads.info.
- Processed data types:
- Content data (e.g. textual or visual messages and contributions as well as the information relating to them, such as information on authorship or time of creation);
- Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions);
- Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
- Event data (Facebook) ("Event data" is information that is sent to the provider Meta via Meta pixels (whether via apps or other channels), for example, and relates to people or their actions. This data includes, for example, details of website visits, interactions with content and functions, app installations and product purchases. Event data is processed with the aim of creating target groups for content and advertising messages (custom audiences). It is important to note that event data does not include actual content such as comments written, login information or contact information such as names, email addresses or telephone numbers. "Event data" is deleted by Meta after a maximum of two years, and the target groups created from it disappear when our Meta user accounts are deleted).
- Data subjects:
- Users (e.g. website visitors, users of online services).
- Purposes of processing:
- Reach measurement (e.g. access statistics, recognising returning visitors);
- Tracking (e.g. interest/behavioural profiling, use of cookies);
- Conversion measurement (measurement of the effectiveness of marketing measures);
- Target group formation;
- Marketing;
- Profiles with user-related information (creation of user profiles);
- Provision of our online services and user-friendliness;
- remarketing.
- Click tracking.
- Storage and deletion:
- Deletion in accordance with the information in the section
"General information on data storage and deletion". - Storage of cookies for up to 2 years (Unless otherwise stated, cookies and similar storage methods may be stored on users' devices for a period of two years).
- Deletion in accordance with the information in the section
- Security measures:
- IP masking (pseudonymisation of the IP address).
- Legal basis:
- Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
- Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing processes, procedures and services:
- Meta pixel and target group formation (custom audiences): With the help of the meta pixel (or comparable functions, for the transmission of event data or contact information via interfaces in apps), it is possible for the Meta company to determine the visitors to our online offer as a target group for the display of adverts (so-called "meta ads"). Accordingly, we use the meta pixel to display the meta ads placed by us only to those users on Meta platforms and within the services of Meta's cooperating partners (so-called "Audience Network " https://www.facebook.com/audiencenetwork/) who have also shown an interest in our online offering or who have certain characteristics (e.g. interest in certain topics or products that can be seen from the websites visited) that we transmit to Meta (so-called "custom audiences"). With the help of the meta pixel, we also want to ensure that our meta ads correspond to the potential interest of users and are not annoying. With the help of the meta pixel, we can also track the effectiveness of the meta ads for statistical and market research purposes by seeing whether users have been redirected to our website after clicking on a meta ad (so-called "conversion measurement");
Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland;
Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR);
Website: https://www.facebook.com;
Privacy Policy: https://www.facebook.com/about/privacy;
Data processing agreement: https://www.facebook.com/legal/terms/dataprocessing;
Basis for third country transfers: Data Privacy Framework (DPF);
Further information: Event user data, i.e. behavioural and interest data, is processed for the purposes of targeted advertising and target group formation on the basis of the joint controllership agreement ("Controller Addendum", https://www.facebook.com/legal/controller_addendum). Joint controllership is limited to the collection by and transfer of data to Meta Platforms Ireland Limited, a company based in the EU. The further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, which in particular concerns the transfer of data to the parent company Meta Platforms, Inc. in the USA (on the basis of the standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.) - Facebook Ads: Placement of adverts within the Facebook platform and analysis of the ad results;
Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland;
Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR);
Website: https://www.facebook.com;
Privacy Policy: https://www.facebook.com/about/privacy;
Basis for third country transfers: Data Privacy Framework (DPF);
Opt-Out: We refer to the data protection and advertising settings in the user's profile on the Facebook platforms as well as to Facebook's consent procedures and contact options for exercising information and other data subject rights, as described in Facebook's privacy policy;
Further information: Event user data, i.e. behavioural and interest data, is processed for the purposes of targeted advertising and targeting on the basis of the joint controllership agreement ("Controller Addendum", https://www.facebook.com/legal/controller_addendum). Joint controllership is limited to the collection by and transfer of data to Meta Platforms Ireland Limited, a company based in the EU. The further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, which in particular concerns the transfer of the data to the parent company Meta Platforms, Inc. in the USA (on the basis of the standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.) - Google Ads and conversion measurement: online marketing process for the purpose of placing content and adverts within the service provider's advertising network (e.g. in search results, in videos, on websites, etc.) so that they are displayed to users who have a presumed interest in the adverts. In addition, we measure the conversion of the adverts, i.e. whether users have taken them as an opportunity to interact with the adverts and use the advertised offers (so-called "conversions"). However, we only receive anonymous information and no personal information about individual users;
Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland;
Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR);
Website: https://marketingplatform.google.com;
Privacy Policy: https://policies.google.com/privacy;
Basis for third country transfers: Data Privacy Framework (DPF);
Further information: Types of processing and data processed: https: //business.safety.google/adsservices/. Data processing conditions between controllers and standard contractual clauses for third country transfers of data: https: //business.safety.google/adscontrollerterms. - Google Ads Remarketing: Google Remarketing, also known as retargeting, is a technology that allows users who use an online service to be added to a pseudonymous remarketing list so that users can be shown adverts on other online offers based on their visit to the online service;
Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland;
Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR);
Website: https://marketingplatform.google.com;
Privacy Policy: https://policies.google.com/privacy;
Basis for third country transfers: Data Privacy Framework (DPF);
Further information: Types of processing and data processed: https: //business.safety.google/adsservices/. Data processing conditions between controllers and standard contractual clauses for third country transfers of data: https: //business.safety.google/adscontrollerterms. - Instagram Ads: Placement of ads within the Instagram platform and evaluation of ad results;
Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland;
Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR);
Website: https://www.instagram.com;
Privacy Policy: https://instagram.com/about/legal/privacy;
Basis for third country transfers: Data Privacy Framework (DPF);
Opt-Out: We refer to the data protection and advertising settings in the user's profile on the Instagram platform and as part of Instagram's consent procedure and Instagram's contact options for exercising information and other data subject rights in Instagram's privacy policy;
Further information: Event user data, i.e. behavioural and interest data, is processed for the purposes of targeted advertising and targeting on the basis of the joint controllership agreement ("Controller Addendum", https://www.facebook.com/legal/controller_addendum). Joint controllership is limited to the collection by and transfer of data to Meta Platforms Ireland Limited, a company based in the EU. The further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, which in particular concerns the transfer of the data to the parent company Meta Platforms, Inc. in the USA (on the basis of the standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.) - UTM parameter: Analysis of sources and user actions based on an extension of web addresses referring to us with an additional parameter, the "UTM" parameter. For example, a UTM parameter "utm_source=platformX &utm_medium=video" can tell us that a person has clicked on the link on platform X within a video. The UTM parameters provide information about the source of the link, the medium used (e.g. social media, website, newsletter), the type of campaign or the content of the campaign (e.g. post, link, image and video). With the help of this information, we can, for example, check our visibility on the Internet or the effectiveness of our campaigns;
Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
24 Digital badges
Digital badges, also known as open badges (hereinafter referred to as "badges"), are digital certificates that confirm the skills, achievements and interests of individuals or organisations. They are issued by credible organisations. The badges are labelled with metadata and information about the skills and achievements acquired. Typically, badges are represented by an image or a digital certificate containing details of the recipient, issuer, metadata and other relevant information.
If badges are issued individually for specific persons, the metadata stored in the badges and used to assign the skills, achievements and interests of the persons concerned are processed.
If cookies and comparable technologies that are not required are used as part of the badges and therefore or otherwise require the consent of the users, we obtain the corresponding consent of the users and inform them accordingly.
- Processed data types:
- Inventory data (e.g. full name, residential address, contact information, etc.);
- Content data (e.g. textual or visual messages and contributions as well as the information relating to them, such as information on authorship or time of creation).
- Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions).
- Data subjects:
- Service recipients and clients; users (e.g. website visitors, users of online services).
- Business and contractual partners.
- Purposes of the processing:
- Marketing; provision of our online services and user-friendliness.
- Public relations and information purposes.
- Storage and deletion:
- Deletion in accordance with the information in the section
"General information on data storage and deletion". - Deletion after cancellation.
- Deletion in accordance with the information in the section
- Legal basis:
- Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
- Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing processes, procedures and services:
- StudyCheck: We have integrated the StudyCheck rating seal ("rating seal") on our website, which is displayed to you and allows you to view collected student opinions about our study programmes. The rating seal and the services advertised with it are an offer from OAK - Online Akademie GmbH, Zollstockgürtel 63
50969 Cologne.
Further information on data protection can be found at www.studycheck.de/datenschutz. For the integration of the rating seal and the retrieval of student opinions, it is technically necessary to process your IP address so that the content can be sent to your browser. Your IP address is therefore transmitted to OAK - Online Akademie GmbH. OAK - Online Akademie GmbH does not use any tracking cookies or comparable technologies within the plugin. Your IP address will be automatically deleted by OAK - Online Akademie GmbH no later than 12 months after it has been collected. This data processing is carried out to protect our legitimate interest in the optimisation and economic operation of our website and is technically necessary for the integration of the rating seal. The legal basis is Art. 6 para. 1 lit. f) GDPR;
Service provider: OAK - Online Akademie GmbH, Zollstockgürtel 63, 50969 Cologne, Germany;
Website: https://www.studycheck.de/.
Privacy Policy: https://www.studycheck.de/datenschutz.
25 Presence in social networks (social media)
We maintain online presences within social networks and process user data in this context 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 may result in risks for users because, for example, it could make it more difficult to enforce user 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 behaviour and the resulting interests of users. The latter may in turn be used, for example, to place adverts within and outside the networks that presumably correspond to the interests of the users. Cookies are therefore generally stored on users' computers, in which the user behaviour and interests of the users are stored. In addition, data can also be stored in the user profiles independently of the devices used by the users (especially if they are members of the respective platforms and are logged in there).
For a detailed description of the respective forms of processing and the opt-out options, please refer to the data protection declarations 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 also like to point out that these can be asserted most effectively with the providers. Only the latter have access to the user data and can take appropriate measures and provide information directly. Should you nevertheless require assistance, you can contact us.
- Processed data types:
- Contact data (e.g. postal and e-mail addresses or telephone numbers);
- Content data (e.g. textual or visual messages and contributions as well as the information relating to them, such as information on authorship or time of creation).
- Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions).
- Data subjects:
- Users (e.g. website visitors, users of online services).
- Purposes of the processing:
- Communication; feedback (e.g. collecting feedback via online form).
- Public relations work.
- Storage and deletion:
- Deletion in accordance with the information in the section
"General information on data storage and deletion".
- Deletion in accordance with the information in the section
- Legal bases:
- Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing processes, procedures and services:
- Instagram: Social network;
Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland;
Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR);
Website: https://www.instagram.com;
Privacy Policy: https://instagram.com/about/legal/privacy.
Basis for third country transfers: Data Privacy Framework (DPF). - Facebook pages: Profiles within the social network Facebook - We are jointly responsible with Meta Platforms Ireland Limited for the collection (but not the further processing) of data from visitors to our Facebook page (so-called "fan page"). This data includes information about the types of content users view or interact with, or the actions they take (see under "Things you and others do and provide" in the Facebook Data Policy: https://www.facebook.com/policy), as well as information about the devices used by users (e.g. IP addresses, operating system, browser type, language settings, cookie data; see under "Device information" in the Facebook Data Policy: www.facebook.com/policy). As explained in the Facebook Data Policy under "How do we use this information?", Facebook also collects and uses information to provide analytics services, so-called "Page Insights", for page operators to gain insights into how people interact with their pages and the content associated with them. We have concluded a special agreement with Facebook ("Information on Page Insights", https://www.facebook.com/legal/terms/page_controller_addendum), which regulates in particular which security measures Facebook must observe and in which Facebook has agreed to fulfil the rights of data subjects (i.e. users can, for example, send information or deletion requests directly to Facebook). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook. Further information can be found in the "Information on Page Insights"(https://www.facebook.com/legal/terms/information_about_page_insights_data). The joint responsibility is limited to the collection by and transfer of data to Meta Platforms Ireland Limited, a company based in the EU. The further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, which in particular concerns the transfer of data to the parent company Meta Platforms, Inc. in the USA;
service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland;
Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR);
Website: https://www.facebook.com;
Privacy Policy: https://www.facebook.com/policy.
Basis for third country transfers: Data Privacy Framework (DPF). - LinkedIn: Social network - We are jointly responsible with LinkedIn Ireland Unlimited Company for the collection (but not the further processing) of data of visitors that are created for the purpose of creating the "page insights" (statistics) of our LinkedIn profiles.
This data includes information about the types of content users view or interact with, or the actions they take, as well as information about the devices used by users (e.g. IP addresses, operating system, browser type, language settings, cookie data) and information from the user's profile, such as job function, country, industry, hierarchy level, company size and employment status. Data protection information on the processing of user data by LinkedIn can be found in LinkedIn's data protection information: https://www.linkedin.com/legal/privacy-policy
We have concluded a special agreement with LinkedIn Ireland ("Page-Insights Joint Controller Addendum (the 'Addendum')", https://legal.linkedin.com/pages-joint-controller-addendum), which regulates in particular which security measures LinkedIn must observe and in which LinkedIn has agreed to fulfil the rights of data subjects (i.e. users can, for example, send information or deletion requests directly to LinkedIn). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with LinkedIn. Joint responsibility is limited to the collection of data by and transfer to Ireland Unlimited Company, a company based in the EU. The further processing of the data is the sole responsibility of Ireland Unlimited Company, which in particular concerns the transfer of data to the parent company LinkedIn Corporation in the USA;
service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland;
Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR);
Website: https://www.linkedin.com;
Privacy Policy: https://www.linkedin.com/legal/privacy-policy;
Basis for third country transfers: Data Privacy Framework (DPF).
Opt-out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out. - TikTok: Social network / video platform;
Service provider: TikTok Technology Limited, 10 Earlsfort Terrace, Dublin, D02 T380, Ireland and TikTok Information Technologies UK Limited, Kaleidoscope, 4 Lindsey Street, London, United Kingdom, EC1A 9HP;
Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR);
Website: https://www.tiktok.com.
Privacy Policy: https://www.tiktok.com/de/privacy-policy. - X: Social network;
Service provider: Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2 D02 AX07, Ireland;
Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Privacy Policy: https://twitter.com/privacy,(Settings: https: //twitter.com/personalization). - YouTube: Social network and video platform;
Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland;
Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR);
Privacy Policy: https://policies.google.com/privacy;
Basis for third country transfers: Data Privacy Framework (DPF).
Opt-Out: https://myadcenter.google.com/personalizationoff.
26 Plug-ins and embedded functions and content
We integrate functional and content elements into our online offering that are obtained from the servers of their respective providers (hereinafter referred to as "third-party providers"). These may be, for example, graphics, videos or city maps (hereinafter uniformly referred to as "content").
The integration always requires that the third-party providers of this content process the IP address of the user, as they would not be able to send the content to their browser without the IP address. The IP address is therefore required to display this content or function. We endeavour to only use content whose respective providers only use the IP address to deliver the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. Pixel tags can be used to analyse information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user's device and may contain, among other things, technical information about the browser and operating system, referring websites, visiting time and other information about the use of our online offering, but may also be linked to such information from other sources.
Notes on legal bases:
If we ask users for their consent to the use of third-party providers, the legal basis for data processing is permission. Otherwise, user data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.
- Processed data types:
- Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions);
- Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
- Location data (information on the geographical position of a device or person).
- Data subjects:
- Users (e.g. website visitors, users of online services).
- Purposes of the processing:
- Provision of our online services and user-friendliness.
- Security measures.
- Storage and erasure:
- Deletion in accordance with the information in the section
"General information on data storage and deletion". - Storage of cookies for up to 2 years (Unless otherwise stated, cookies and similar storage methods may be stored on users' devices for a period of two years).
- Deletion in accordance with the information in the section
- Legal basis:
- Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
- Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing processes, procedures and services:
- Google Maps: We integrate the maps of the "Google Maps" service of the provider Google. The processed data may include, in particular, IP addresses and user location data;
Service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson's Quay, Dublin 2, Ireland;
Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR);
Website: https://mapsplatform.google.com/;
Privacy Policy: https://policies.google.com/privacy.
Basis for third country transfers: Data Privacy Framework (DPF). - YouTube videos: Video content; YouTube videos are integrated via a special domain (recognisable by the component "youtube-nocookie") in the so-called "extended data protection mode", whereby no cookies are collected on user activities in order to personalise video playback. However, information on user interaction with the video (e.g. remembering the last playback point) may be stored;
Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland;
Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR);
Website: https://www.youtube.com;
Privacy Policy: https://policies.google.com/privacy.
Basis for third country transfers: Data Privacy Framework (DPF). - Turnstile: CAPTCHA service used to check whether the data entered within our online offering (e.g. on a login page or a contact form) has been entered by a human or an automated programme. For this purpose, the service analyses the behaviour of users of our online offering based on various characteristics. This analysis begins automatically as soon as a user uses our online offering. Various information is evaluated for the analysis (IP address, time spent by the visitor on the website or app or mouse movements of the user as well as technical information on the end device and browser used by the user);
Service provider: Cloudflare, Inc, 101 Townsend St, San Francisco, CA 94107, USA;
Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR);
Website: https://www.cloudflare.com/lp/turnstile/;
Privacy Policy: https://www.cloudflare.com/privacypolicy/;
Data processing agreement: https://www.cloudflare.com/cloudflare-customer-dpa/.
Basis for third country transfers: Data Privacy Framework (DPF).
27 Application procedure (workplace)
The application procedure (job) requires applicants to provide us with the data necessary for their assessment and selection. The information required can be found in the job description or, in the case of online forms, in the details provided there.
In principle, the required information includes personal details such as name, address, contact details and proof of the qualifications required for the position. On request, we will be happy to provide additional information on what details are required.
If available, applicants are welcome to submit their applications via our online form, which is encrypted using state-of-the-art technology. For the purposes of searching for applicants, submitting applications and selecting applicants, we may use applicant management or recruitment software and platforms and services from third-party providers in compliance with legal requirements.
Processing of special categories of data: Insofar as special categories of personal data (Art. 9 para. 1 GDPR, e.g. health data, such as severely disabled status or ethnic origin) are requested from applicants or communicated by them as part of the application process, their processing is carried out so that the controller or the data subject can exercise the rights arising from labour law and social security and social protection law and fulfil his or her obligations in this regard. In the case of the protection of vital interests of applicants or other persons or for the purposes of preventive health care or occupational medicine, for the assessment of the employee's fitness for work, for medical diagnosis, for the provision of health or social care or treatment or for the management of health or social care systems and services.
Deletion of data: The data provided by applicants may be further processed by us for the purposes of the employment relationship in the event of a successful application. Otherwise, if the application for a job offer is unsuccessful, the applicant's data will be deleted. Applicants' data will also be deleted if an application is withdrawn, which applicants are entitled to do at any time. Subject to a justified cancellation by the applicant, the deletion will take place at the latest after a period of six months so that we can answer any follow-up questions about the application and fulfil our obligations to provide evidence under the regulations on equal treatment of applicants. Invoices for any reimbursement of travel expenses will be archived in accordance with tax regulations.
Inclusion in an applicant pool: Inclusion in an applicant pool, if offered, is based on consent. Applicants are informed that their consent to inclusion in the talent pool is voluntary, has no influence on the ongoing application process and that they can revoke their consent at any time for the future.
- Processed data types:
- Inventory data (e.g. full name, home address, contact information, etc.);
- Contact data (e.g. postal and e-mail addresses or telephone numbers);
- Content data (e.g. textual or visual messages and contributions as well as the information relating to them, such as information on authorship or time of creation).
- Applicant data (e.g. personal details, postal and contact addresses, the documents belonging to the application and the information contained therein, such as cover letter, CV, certificates and other personal or qualification information provided with regard to a specific position or voluntarily by applicants).
- Data subjects:
- Applicants.
- Purposes of the processing:
- Application procedure (justification and possible subsequent implementation as well as possible subsequent termination of the employment relationship).
- Storage and deletion:
- Deletion in accordance with the information in the section
"General information on data storage and deletion".
- Deletion in accordance with the information in the section
- Legal basis:
- Application procedure as a pre-contractual or contractual relationship (Art. 6 para. 1 sentence 1 lit. b) GDPR).
- Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing processes, procedures and services:
- Softgarden applicant management software:
Services in connection with employee acquisition/recruitment (search for employees, communication, application process, contract negotiations);
Service provider: softgarden e-recruiting GmbH, Tauentzienstraße 14, 10789 Berlin, Germany;
Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR);
Website: https://www.softgarden.de;
Privacy Policy: https://softgarden.com/de/datenschutz-software-und-service/
Basis for third country transfers: Standard Contractual Clauses (conclusion with subcontractors with regard to the storage of data in the USA).
Deletion of data: The application documents in the applicant pool will be processed solely in the context of future job advertisements and the search for employees and will be destroyed at the latest after the specified period has expired. Applicants are informed that their consent to inclusion in the applicant pool is voluntary, has no influence on the current application process and that they can revoke this consent at any time for the future.
Part III - Specific processing activities
28 Application for a study place (student application)
As part of the student application procedure, we process all information submitted by you that is required to carry out the procedure on the basis of Article 6(1)(b) GDPR.
Once the selection of applicants has been completed, your data will be deleted with the exception of your surname, first name, date of birth and date of application. This part of your data is stored in order to safeguard our own legitimate interests in accordance with Article 6(1)(f) GDPR, as the number of repeat applications at Witten/Herdecke University is limited and must be documented. We store this data for a period of 5 years.
- Processed data types:
- Inventory data
- contact data
- Content data
- Applicant data
- Data subjects
- Applicants (study place)
- Purposes of the processing:
- Implementation of the application procedure (examination of requirements, organisation of the selection seminar)
- Storage and deletion:
- The application data is processed in accordance with the information in the section
"General information on data storage and deletion" - Part of the inventory data (surname, first name, date of birth and date of application) is stored for a period of 5 years
- The application data is processed in accordance with the information in the section
- Legal basis:
- Application procedure: Art. 6 (1) b GDPR, processing is necessary for the organisation of a pre-contractual relationship
- 5-year storage: Art. 6 (1) f GDPR, legitimate self-interest of the UW
29 University bibliography
The university bibliography is maintained by the UW/H editorial team. If you have any questions, please contact:
The processing of your data as part of the university bibliography serves, among other things, to make academic research results available to the (specialised) public.
In the context of the university bibliography, the processing of personal data of authors, editors and other persons involved in a work is carried out on the basis of Art. 6 (1) e GDPR, for the "performance of a task [...] carried out in the public interest".
The processing of personal data required for system maintenance is carried out on the basis of Art. 6 (1) b GDPR within the scope of the employment relationship.
The recipient of the published data is the general (specialised) public.
The university bibliography is operated as a joint service ("university bibliography") of the university libraries of TU Dortmund University and Ruhr-Universität Bochum. There is an agreement between the UW/H and the operating neighbouring universities on order processing in accordance with Art. 28 GDPR.
Sensitive personal data in accordance with Art. 9 (1) GDPR are not processed.
- Processed data types:
- Publication data
- Persons affected:
- Authors,
- publishers and
- other persons involved in a work
- Purposes of the processing:
- Provision of scientific research results for the
(specialised) public.
- Provision of scientific research results for the
- Storage and deletion:
- The information processed for scientific publication remains permanently stored in the database. The university bibliography is an archive system.
- Legal basis:
- Works: Art. 6 (1) e GDPR, "performance of a task [...] carried out in the public interest".
- System maintenance: Art. 6 (1) b GDPR in the context of the employment relationship.
30 UW/H Alumni Management
The Alumni Management department is responsible for the management of personal data of alumni. If you have any questions, please contact: Alumni@uni-wh.de.
Alumni are members of the university via the UW/H constitution. It is therefore important to UW/H Alumni Management to remain in contact with you after your studies and to keep you informed about selected offers and news relating to your alma mater. In this way, we can shape the future of UW/H together and experience it together. For the UW/H Alumni Management, we take over the last known inventory data from the UW/H student administration. The legal basis for this is Article 6(1)(f) GDPR. We process the data that you voluntarily provide us with in addition or in correction on the basis of Art. 6 para. 1 letter a GDPR.
- Processed data types:
- Inventory data
- contact data
- Content data
- Data subjects concerned:
- Alumnae and alumni of the UW/H
- Purposes of the processing:
- Maintaining contact
- Exchange of information
- Storage and deletion:
- The UW/H Alumni Management will process the data you provide until you withdraw your consent.
- Inventory and contact data are processed permanently. Cancellation is possible.
- Legal basis:
- Transfer of inventory and contact data: Art. 6 (1) f GDPR, legitimate self-interest of the UW/H in maintaining contact with alumni
- Collection of further content: Art. 6 (1) a GDPR, consent
- Possibility of cancellation:
- If you wish to withdraw your consent, please contact UW/H Alumni Management at .
- The same applies if you wish to object to the processing of your inventory and contact data.
31 Administration of donations (twingle donation form)
This website uses the donation form of twingle GmbH, Prinzenallee 74, 13357 Berlin(https://www.twingle.de/). For this donation form, twingle GmbH provides the technical platform for the donation process. The data you enter when making a donation (e.g. address, bank details, etc.) will only be stored by twingle on servers in Germany for the purpose of processing the donation.
We have concluded a contract with twingle for order data processing.
Your data is processed on the basis of Art. 6 (1) (a) General Data Protection Regulation (GDPR) (consent) and Art. 6 (1) (b) General Data Protection Regulation (GDPR) (processing for the fulfilment of a contract, insofar as the provision of the data is necessary for the processing of the donation process). If you have given your consent to data processing, you can withdraw your consent at any time. A revocation does not affect the effectiveness of data processing operations in the past.
When you make a donation, we collect and use your personal data only to the extent necessary to fulfil and process your donation and, if applicable, to process your enquiries. If you do not provide your data, we will not be able to receive your donation.
Your data will not be passed on to third parties without your express consent. The only exception to this is the company twingle GmbH as a service partner, which we use to process the donation as part of order processing. For its part, twingle GmbH uses payment service providers and service providers as sub-processors for the dispatch of the donation receipt. The scope of data transfer is always kept to a minimum. Further information on data protection at twingle GmbH can be found here: https: //www.twingle.de/datenschutz/
- Processed data types:
- Personal data (e.g. name, address, email address)
- Payment data (e.g. IBAN, BIC)
- Data subjects concerned:
- Donors
- Employees (processors)
- Purposes of the processing:
- Donation management
- Storage and deletion:
- Deletion in accordance with the information in the section
"General information on data storage and deletion".
- Deletion in accordance with the information in the section
- Legal basis:
- Acceptance of donations: Art. 6 (1) a General Data Protection Regulation (GDPR), "consent" and Art. 6 (1) b General Data Protection Regulation (GDPR), "fulfilment of a contractual relationship"
- Possibility of cancellation:
- If you have given your consent to data processing, you can withdraw your consent at any time.
Part IV - Update note and glossary
32 Changes and updates
We ask you to inform yourself regularly about the content of our privacy policy. We will amend the privacy policy as soon as changes to the data processing carried out by us make this necessary. We will inform you as soon as the changes require your co-operation (e.g. consent) or other individual notification.
If we provide addresses and contact information of companies and organisations in this privacy policy, please note that the addresses may change over time and please check the information before contacting us.
33 Definitions of terms (glossary)
This section provides you with an overview of the terms used in this privacy policy. Insofar as the terms are defined by law, their legal definitions apply. However, the following explanations are primarily intended to aid understanding.
- Inventory data: Inventory data includes essential information that is necessary for the identification and management of contractual partners, user accounts, profiles and similar assignments. This data may include personal and demographic information such as names, contact information (addresses, telephone numbers, e-mail addresses), dates of birth and specific identifiers (user IDs). Inventory data forms the basis for any formal interaction between people and services, facilities or systems by enabling clear assignment and communication.
- Content data: Content data includes information generated in the course of creating, editing and publishing content of all kinds. This category of data can include texts, images, videos, audio files and other multimedia content published on various platforms and media. Content data is not limited to the actual content, but also includes metadata that provides information about the content itself, such as tags, descriptions, author information and publishing dates
- Click tracking: Click tracking allows you to keep track of users' movements within an entire online offering. Since the results of these tests are more accurate if user interaction can be tracked over a certain period of time (e.g. so that we can find out whether a user likes to return), cookies are usually stored on users' computers for these test purposes.
- Contact details: Contact data is essential information that enables communication with people or organisations. They include telephone numbers, postal addresses and email addresses, as well as communication tools such as social media handles and instant messaging identifiers.
- Conversion measurement: Conversion measurement (also referred to as "visit action evaluation") is a procedure that can be used to determine the effectiveness of marketing measures. For this purpose, a cookie is usually stored on the user's device within the websites on which the marketing measures take place and then retrieved again on the target website. For example, this allows us to track whether the adverts we have placed on other websites have been successful.
- Meta, communication and process data: Meta data, communication data and procedural data are categories that contain information about how data is processed, transmitted and managed. Meta data, also known as data about data, includes information that describes the context, origin and structure of other data. It can include information about the file size, the creation date, the author of a document and the change histories. Communication data records the exchange of information between users via various channels, such as e-mail traffic, call logs, messages in social networks and chat histories, including the persons involved, time stamps and transmission paths. Process data describes the processes and procedures within systems or organisations, including workflow documentation, logs of transactions and activities, and audit logs used to track and review processes.
- Member data: Member data includes information relating to the individuals who are part of an organisation, association, online service or other group. This data is used to manage memberships, enable communication and provide services or benefits associated with membership. Member data may include personal identification information, contact information, information on membership status and duration, contribution payments, participation in events and activities as well as preferences and interests. It may also include data about the use of the organisation's services. This data is collected and processed in compliance with data protection regulations and is used both for administrative purposes and to promote member engagement and satisfaction.
- Usage data: Usage data refers to information that captures how users interact with digital products, services or platforms. This data includes a wide range of information that shows how users use applications, which functions they favour, how long they stay on certain pages and which paths they take to navigate through an application. Usage data can also include frequency of use, timestamps of activities, IP addresses, device information and location data. It is particularly valuable for analysing user behaviour, optimising user experiences, personalising content and improving products or services. In addition, usage data plays a crucial role in recognising trends, preferences and potential problem areas within digital offerings
- 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. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
- Profiles with user-related information: The processing of "profiles with user-related information", or "profiles" for short, includes any type of automated processing of personal data that consists of using this personal data to identify certain personal aspects relating to a natural person (depending on the type of profiling, this may include various information relating to demographics, behaviour and interests, such asDepending on the type of profiling, this may include various information regarding demographics, behaviour and interests, such as interaction with websites and their content, etc.), to analyse, evaluate or predict them (e.g. interests in certain content or products, click behaviour on a website or location). Cookies and web beacons are often used for profiling purposes.
- Log data: Log data is information about events or activities that have been logged in a system or network. This data typically contains information such as timestamps, IP addresses, user actions, error messages and other details about the use or operation of a system. Log data is often used to analyse system problems, for security monitoring or to create performance reports.
- Reachmeasurement: Reach measurement (also known as web analytics) is used to evaluate the flow of visitors to an online offering and can include the behaviour or interests of visitors in certain information, such as website content. With the help of reach analysis, operators of online services can, for example, recognise at what time users visit their websites and what content they are interested in. This allows them to better customise the content of their websites to the needs of their visitors, for example. Pseudonymous cookies and web beacons are often used for reach analysis purposes in order to recognise returning visitors and thus obtain more precise analyses of the use of an online offering.
- Remarketing: The term "remarketing" or "retargeting" is used when, for example, it is noted for advertising purposes which products a user was interested in on a website in order to remind the user of these products on other websites, e.g. in adverts.
- Location data: Location data is generated when a mobile device (or another device with the technical requirements for location determination) connects to a radio cell, a WLAN or similar technical means and functions of location determination. Location data is used to indicate the geographically determinable position on earth at which the respective device is located. Location data can be used, for example, to display map functions or other location-dependent information.
- Tracking: The term "tracking" is used when the behaviour of users can be traced across several online offers. As a rule, behavioural and interest information is stored in cookies or on the servers of the providers of the tracking technologies with regard to the online services used (so-called profiling). This information can then be used, for example, to display adverts to users that are likely to correspond to their interests.
- Controller: "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.
- Processing: "Processing" means any operation or set of operations which is performed on personal data, whether or not by automated means. The term is broad and encompasses practically every handling of data, whether it is collection, analysis, storage, transmission or erasure.
- Contract data: Contract data is specific information that relates to the formalisation of an agreement between two or more parties. It documents the conditions under which services or products are provided, exchanged or sold. This category of data is essential for the management and fulfilment of contractual obligations and includes both the identification of the contracting parties and the specific terms and conditions of the agreement. Contract data may include start and end dates of the contract, the type of services or products agreed, price agreements, payment terms, cancellation rights, renewal options and special terms or clauses. They serve as the legal basis for the relationship between the parties and are crucial for the clarification of rights and obligations, the enforcement of claims and the resolution of disputes.
- Payment data: Payment data includes all information needed to process payment transactions between buyers and sellers. This data is crucial for e-commerce, online banking and any other form of financial transaction. It includes details such as credit card numbers, bank details, payment amounts, transaction data, verification numbers and billing information. Payment data can also include information about payment status, chargebacks, authorisations and fees.
- Target group formation: Target group formation ("custom audiences") is when target groups are determined for advertising purposes, e.g. the display of adverts. For example, based on a user's interest in certain products or topics on the internet, it can be concluded that this user is interested in adverts for similar products or the online shop in which they viewed the products. In turn, "lookalike audiences" (or similar target groups) are when the content deemed suitable is displayed to users whose profiles or interests presumably correspond to the users for whom the profiles were created. For the purposes of creating custom audiences and lookalike audiences