This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.
In this policy, “we”, “us” and “our” refer to the Institute of Behavioral Science and Technology of the University of St. Gallen.
2. How we use your personal data
In this Section 2 we have set out:
- the general categories of personal data that we may process;
- in the case of personal data that we did not obtain directly from you, the source and specific categories of that data
- the purposes for which we may process personal data; and
- the legal bases of the processing.
We may process data about your use of our website and services (“usage data“). The usage data may include your geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system Google Analytics. This usage data may be processed for the purposes of analyzing the use of the website and services. The legal basis for this processing is your consent and our legitimate interests, namely monitoring and improving our website and services.
We may process information contained in any enquiry you submit to us regarding services, namely order programmes and registration for events (“enquiry data“). The enquiry data may include your salutation, first name, last name, email address, mobile phone number, programme interested, place of residence, city, post code, country, company, language. The enquiry data may be processed for the purpose of supplying the services mentioned above and keeping proper records of those transactions. The legal basis for this processing is consent.
We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.
We may process information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
Please do not supply any other person’s personal data to us, unless we prompt you to do so.
3. Providing your personal data to others
We may disclose your personal data to any member of the University of St.Gallen insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy. Information about our institutes and schools can be found at https://www.unisg.ch/en/universitaet/institute and https://www.unisg.ch/en/universitaet/schools.
We may disclose your personal data to professional advisers insofar as reasonably necessary for the purposes of obtaining professional advice.
We may disclose (“usage Data“) to our advertising, analytics and social media providers insofar as is reasonably necessary to measure the success of and improve our advertising and social media efforts. This personal data may include IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. These advertising providers include Facebook, Google Adwords, Google DoubleClick, LinkedIn, AddToAny and Youtube.
In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
4. International transfers of your personal data
In this Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside Switzerland and the European Economic Area (EEA).
Our Analytics Provider, Google Analytics, is situated in the United States of America. The European Commission has made an “adequacy decision” with respect to the General Data Protection Regulation. Transfers to the United States of America will be protected by appropriate safeguards, namely the EU-US Privacy Shield framework of which Google Analytics is a signatory. Information on the framework can be found here: https://www.privacyshield.gov/
Our Advertising and Social Media providers, listed in section 3, are located in the United States of America. The European Commission has made an “adequacy decision” with respect to the General Data Protection Regulation. Transfers to the United States of America will be protected by appropriate safeguards, namely the EU-US Privacy Shield framework of which all our advertising and social media providers are signatories. Information on the framework can be found here: https://www.privacyshield.gov/
5. Retaining and deleting personal data
This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
We will retain your personal data for a minimum of time.
It is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:
- the period of retention of Usage Data will be determined based on user requests for deletion or the data is no longer required.
- the period of retention for Enquiry Data will be determined based on user requests for deletion or the data is no longer required.
- the period of retention for Notification Data will be determined based on user requests for deletion.
- the period of retention for Correspondence Data will be determined based on user requests for deletion or the data is no longer required and the correspondence has been completed.
Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
6. Your rights
In this Section 7, we have summarized the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
Your principal rights under data protection law are:
- the right to access;
- the right to rectification;
- the right to erasure;
- the right to restrict processing;
- the right to object to processing;
- the right to data portability;
- the right to complain to a supervisory authority; and
- the right to withdraw consent.
You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data.
You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for compliance with a legal obligation; or for the exercise or defense of legal claims.
In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defense of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the exercise or defense of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the exercise or defense of legal claims.
You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
To the extent that the legal basis for our processing of your personal data is:
- consent; or
- that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, Switzerland, your place of work or the place of the alleged infringement.
To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
You may exercise any of your rights in relation to your personal data by email or written notice to us. We may require a proof of identity.
7. Hosting Provider & Server Log Files
The provider of the pages automatically collects and stores information in so-called server log files, which your browser automatically transmits to us. These are:
- IP address
- browser type and browser version
- Operating system used
- referrer URL
- Host name of the accessing computer
- Time of the server request
By registering for the newsletter, you provide your email. Furthermore, when you register, your IP address and the date of registration are also stored, the latter only for evidence purposes in case of improper registration. We use the list provider MailChimp to send our newsletter. MailChimp is a service provided by The Rocket Science Group, LLC, 512 Means Street, Suite 404, Atlanta, GA 30318 (“Rocket”). The data stored during registration is encrypted and transmitted to Rocket and stored by Rocket. Furthermore, MailChimp offers various analytics about how the sent newsletters are opened and used, e.g. to how many users an email was sent, whether emails were rejected and whether users unsubscribed from the list after receiving an email. However, these analyses are only group-related and are not used by us for individual evaluation. MailChimp also uses the Google Analytics analysis tool from Google, Inc and may integrate it into the newsletters. Further details on the data protection of MailChimp www.mailchimp.com/legal/privacy/.
9. Google Analytics
This website uses Google Analytics, a web analytics service provided by Google Inc. 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie (browser type/version, operating system used, referrer URL previously visited website, IP address, time of server request) about your use of this website is usually transmitted to a Google server in the USA and stored there. In the event that IP anonymization is activated on our website, however, your IP address will be truncated beforehand by Google within member states of the European Union or in other contracting states to the Agreement on the European Economic Area.
Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. The IP address transmitted by your browser as part of Google Analytics will not be merged with other data from Google.
This website contain at least one plug-in from YouTube, belonging to Google Inc., located LLC 901 Cherry Ave. San Bruno, CA 94066 USA. As soon as you visit a page of our website that is equipped with a YouTube plug-in, a connection to the YouTube servers is established. In doing so, the YouTube server is informed which specific page of our website you have visited. If, on top of this, you are logged into your YouTube account, you would enable YouTube to assign your surfing behavior directly to your personal profile. You can negate this possibility of association if you log out of your account beforehand. For more information on the collection and use of your data by YouTube, please refer to the privacy notices there at https://www.youtube.com/t/privacy.
11. SSL encryption
This site uses SSL encryption for security reasons and to protect the transmission of confidential content, such as requests that you send to us as the site operator. You can recognize an encrypted connection by the fact that the address line of the browser changes from “http://” to “https://” and by the lock symbol in your browser line. If SSL encryption is activated, the data you transmit to us cannot be read by third parties.