Data Protection

LEGAL

PRIVACY POLICY

DATA PROTECTION DECLARATION ACCORDING TO THE GDPR

I. Name and address of the controller

II. Name and address of the data protection officer

III General information on data processing

IV. Provision of the website and creation of log files

V. Use of cookies

VI Web analysis service Fathom

VII External services (Google, YouTube, etc.)

VIII Rights of the data subject

I. NAME AND ADDRESS OF THE PERSON RESPONSIBLE

The controller within the meaning of the General Data Protection Regulation and other national data protection laws of the member states as well as other data protection regulations is

University of Heidelberg 
Grabengasse 1 
69117 Heidelberg 
Germany

rektorin@rektorat.uni-heidelberg.de

II. NAME AND ADDRESS OF THE DATA PROTECTION OFFICER

The data protection officer of the controller is

Ass. jur. Christoph Wassermann 
Seminarstr. 2 
69117 Heidelberg
+49 6221 54-12070
datenschutz@uni-heidelberg.de

III. GENERAL INFORMATION ON DATA PROCESSING

1. scope of the processing of personal data

We collect and use our users’ personal data only to the extent necessary to provide a functional website and our content and services. The collection and use of our users’ personal data only takes place regularly with the user’s consent. An exception applies in cases where it is not possible to obtain prior consent for factual reasons and the processing of the data is permitted by law.

2. legal basis for the processing of personal data

Insofar as we obtain the consent of the data subject for the processing of personal data, Art. 6 para. 1 lit. a EU General Data Protection Regulation (GDPR) serves as the legal basis for the processing of personal data.

When processing personal data that is necessary for the fulfilment of a contract to which the data subject is a party, Art. 6 para. 1 lit. b GDPR serves as the legal basis. This also applies to processing operations that are necessary for the performance of pre-contractual measures.

Insofar as the processing of personal data is necessary to fulfil a legal obligation to which our company is subject, Art. 6 para. 1 lit. c GDPR serves as the legal basis.

In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 para. 1 lit. d GDPR serves as the legal basis.

If the processing is necessary to safeguard a legitimate interest of our company or a third party and if the interests, fundamental rights and freedoms of the data subject do not outweigh the former interest, Art. 6 para. 1 lit. f GDPR serves as the legal basis for the processing.

3. data erasure and storage duration

The personal data of the data subject will be deleted or blocked as soon as the purpose of storage no longer applies. Data may also be stored if this has been provided for by the European or national legislator in EU regulations, laws or other provisions to which the controller is subject. The data will also be blocked or erased if a storage period prescribed by the aforementioned standards expires, unless there is a need for further storage of the data for the conclusion or fulfilment of a contract.

IV. PROVISION OF THE WEBSITE AND CREATION OF LOG FILES

1. description and scope of data processing

Each time our website is accessed, our system automatically collects data and information from the computer system of the accessing computer.

The following data is collected:

  1. Information about the browser type and version used
  2. The user’s operating system
  3. The IP address of the user
  4. Date and time of access
  5. Websites from which the user’s system accesses our website
  6. Websites that are accessed by the user’s system via our website

The data is also stored in the log files of our system, whereby the IP address is shortened immediately after it is collected, namely an IPv4 address to the first two bytes and an IPv6 address to the first 32 bits. Personal profiles cannot be created with such truncated IP addresses. This data is not stored together with other personal data of the user.

2. legal basis for data processing

The legal basis for the temporary storage of data and log files is Article 6(1)(f) GDPR.

3. purpose of data processing

The temporary storage of the IP address by the system is necessary to enable the website to be delivered to the user’s computer. For this purpose, the user’s IP address must remain stored for the duration of the session.

Data is stored in log files to ensure the functionality of the website. We also use the data to optimise the website and to ensure the security of our information technology systems. The data is not analysed for marketing purposes in this context.

These purposes also constitute our legitimate interest in data processing in accordance with Art. 6 para. 1 lit. f GDPR.

4. duration of storage

The data is deleted as soon as it is no longer required to fulfil the purpose for which it was collected. In the case of the collection of data for the provision of the website, this is the case when the respective session has ended.

If the data is stored in log files, this is the case after seven days at the latest. Storage beyond this period is possible. In this case, the shortening of the user’s IP address means that it is no longer possible to identify the accessing client.

5. possibility of objection and removal

The collection of data for the provision of the website and the storage of data in log files is absolutely necessary for the operation of the website. Consequently, the user has no option to object.

V. USE OF COOKIES

1. description and scope of data processing

Our website uses cookies. Cookies are text files that are stored in the Internet browser or by the Internet browser on the user’s computer system. When a user accesses a website, a cookie may be stored on the user’s operating system. This cookie contains a characteristic string of characters that enables the browser to be uniquely identified when the website is called up again.

We use cookies to provide basic functions on our website. Some elements of our website require that the accessing browser can be identified even after a page change.

2. legal basis for data processing

The legal basis for the processing of personal data using cookies is Art. 6 para. 1 lit. f GDPR.

3. purpose of data processing

The purpose of using technically necessary cookies is to enable the use of websites for users. Some functions of our website cannot be offered without the use of cookies. For these, it is necessary for the browser to be recognised even after a page change.

The user data collected by technically necessary cookies is not used to create user profiles.

These purposes also constitute our legitimate interest in the processing of personal data in accordance with Art. 6 para. 1 lit. f GDPR.

4. duration of storage, possibility of objection and removal

Cookies are stored on the user’s computer and transmitted by it to our website. As a user, you therefore have full control over the use of cookies. You can deactivate or restrict the transmission of cookies by changing the settings in your Internet browser. Cookies that have already been saved can be deleted at any time. This can also be done automatically. If cookies are deactivated for our website, not all functions of the website can be used to their full extent.

VI. WEB ANALYSIS SERVICE FATHOM

1. scope of the processing of personal data

Our website uses Fathom Analytics (www.usefathom.com; provided by Conva Ventures Inc.; hereinafter only referred to as Fathom), a software optimised for data protection for the statistical analysis of website access. Fathom does not store any cookies on your computer. Personal data required for the operation of our website is not transferred to Fathom. Your IP addresses are transmitted to the Fathom server, where they are anonymised before processing and are not stored.

2. legal basis for the processing of personal data

The legal basis for the processing of personal data using cookies is Art. 6 para. 1 lit. f GDPR.

3. purpose of data processing

Fathom is used for the purpose of improving the quality of our website and its content. This enables us to find out how the website is used and to constantly optimise our offering.

4. duration of storage, possibility of objection and removal

Your personal data will not be analysed and stored by Fathom.

Most browsers have a “Do Not Track” option that tells websites not to track your user activity. We have integrated the Fathom integration so that this option is respected and your data is ignored by Fathom.

VII. EXTERNAL SERVICES (GOOGLE, YOUTUBE, ETC.)

We use Google for the provision of search queries. Google uses so-called “cookies”, i.e. text files that are stored on your computer and enable your use of the website to be analysed. The information generated by the cookie about your use of the website (including your non-anonymised IP address) will be transmitted to and stored by Google on servers in the United States. Google may 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. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. By using the search query fields, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

The university makes content from external sources available on its pages; this may be images, documents, scripts, etc. Personal data such as IP address, date of access, etc. are transferred to the external source. We have no influence on the storage period or possible analysis of the data.

We also use frame technology, for example when embedding videos, maps and other external content (e.g. Youtube.com, Vimeo.com, OpenStreetMap). In many places, this cannot be realised in any other way for copyright reasons. This frame technology can result in information being sent to the external provider as soon as the page is accessed, such as non-anonymised IP address and date of access, etc. It also enables the external provider to store cookies on your computer, which can be processed for advertising purposes etc. If you are logged into your YouTube account or Google account, YouTube can assign your surfing behaviour to you personally. To avoid this, you should log out. It is currently not technologically possible to implement an opt-out function here. If you wish to avoid cookies, you can deactivate them in your browser.
  

VIII. RIGHTS OF THE DATA SUBJECT

If your personal data is processed, you are a data subject within the meaning of the GDPR and you have the following rights vis-à-vis the controller:

1. right to information

You can request confirmation from the controller as to whether personal data concerning you is being processed by us.

If such processing has taken place, you can request the following information from the controller:

  1. the purposes for which the personal data are processed;
  2. the categories of personal data that are processed;
  3. the recipients or categories of recipients to whom the personal data concerning you have been or will be disclosed;
  4. the planned duration of storage of the personal data concerning you or, if specific information on this is not possible, criteria for determining the storage period;
  5. the existence of a right to rectification or erasure of personal data concerning you, a right to restriction of processing by the controller or a right to object to such processing;
  6. the existence of a right of appeal to a supervisory authority;
  7. all available information on the origin of the data if the personal data is not collected from the data subject;
  8. the existence of automated decision-making, including profiling, referred to in Art. 22 (1) and (4) GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

You have the right to request information as to whether the personal data concerning you is transferred to a third country or to an international organisation. In this context, you may request to be informed of the appropriate safeguards pursuant to Art. 46 GDPR in connection with the transfer.

This right of access may be restricted to the extent that it is likely to render impossible or seriously impair the realisation of the research or statistical purposes and the restriction is necessary for the fulfilment of the research or statistical purposes.

2. right to rectification

You have a right to rectification and/or completion vis-à-vis the controller if the processed personal data concerning you is incorrect or incomplete. The controller must make the correction without delay.

Your right to rectification may be restricted to the extent that it is likely to render impossible or seriously impair the realisation of the research or statistical purposes and the restriction is necessary for the fulfilment of the research or statistical purposes.

3. right to restriction of processing

Under the following conditions, you may request the restriction of the processing of your personal data:

  1. if you contest the accuracy of the personal data concerning you for a period enabling the controller to verify the accuracy of the personal data;
  2. the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead;
  3. the controller no longer needs the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims, or
  4. if you have objected to the processing pursuant to Art. 21 (1) GDPR and it is not yet certain whether the legitimate grounds of the controller override your grounds.

If the processing of personal data concerning you has been restricted, this data – apart from its storage – may only be processed with your consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.

If the restriction of processing has been restricted in accordance with the above conditions, you will be informed by the controller before the restriction is lifted.

Your right to restriction of processing may be limited to the extent that it is likely to render impossible or seriously impair the realisation of the research or statistical purposes and the restriction is necessary for the fulfilment of the research or statistical purposes.

4. right to cancellation

a. Cancellation obligation

You have the right to obtain from the controller the erasure of personal data concerning you without undue delay and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies:

  1. The personal data concerning you are no longer necessary for the purposes for which they were collected or otherwise processed.
  2. You revoke your consent on which the processing was based pursuant to Art. 6 para. 1 lit. a or Art. 9 para. 2 lit. a GDPR and there is no other legal basis for the processing.
  3. You object to the processing pursuant to Art. 21 (1) GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Art. 21 (2) GDPR.
  4. The personal data concerning you has been processed unlawfully.
  5. The deletion of personal data concerning you is necessary to fulfil a legal obligation under Union law or the law of the Member States to which the controller is subject.
  6. The personal data concerning you was collected in relation to information society services offered in accordance with Art. 8 para. 1 GDPR.
      

b. Information to third parties

If the controller has made the personal data concerning you public and is obliged to erase it pursuant to Art. 17 (1) GDPR, it shall take appropriate measures, including technical measures, taking into account the available technology and the implementation costs, to inform data controllers who process the personal data that you as the data subject have requested the erasure of all links to this personal data or of copies or replications of this personal data.
  

c. Exceptions

The right to erasure does not exist if the processing is necessary

  1. to exercise the right to freedom of expression and information;
  2. for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
  3. for reasons of public interest in the area of public health in accordance with Art. 9 para. 2 lit. h and i and Art. 9 para. 3 GDPR;
  4. for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Art. 89 para. 1 GDPR, insofar as the right referred to in section a) is likely to render impossible or seriously impair the achievement of the objectives of that processing, or
  5. for the assertion, exercise or defence of legal claims.

5. right to information

If you have asserted the right to rectification, erasure or restriction of processing against the controller, the controller is obliged to notify all recipients to whom the personal data concerning you have been disclosed of this rectification or erasure of the data or restriction of processing, unless this proves impossible or involves a disproportionate effort.

You have the right to be informed about these recipients by the controller.

6. right to data portability

You have the right to receive the personal data concerning you, which you have provided to the controller, in a structured, commonly used and machine-readable format. You also have the right to transmit this data to another controller without hindrance from the controller to which the personal data has been provided, where

  1. the processing is based on consent pursuant to Art. 6 para. 1 lit. a GDPR or Art. 9 para. 2 lit. a GDPR or on a contract pursuant to Art. 6 para. 1 lit. b GDPR and
  2. the processing is carried out using automated procedures.

In exercising this right, you also have the right to have the personal data concerning you transmitted directly from one controller to another, where technically feasible. The freedoms and rights of other persons must not be affected by this.

The right to data portability does not apply to the processing of personal data necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

7. right of objection

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.

The controller will no longer process the personal data concerning you unless the controller demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.

If your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data for such marketing, which includes profiling to the extent that it is related to such direct marketing.

If you object to processing for direct marketing purposes, the personal data concerning you will no longer be processed for these purposes.

Notwithstanding Directive 2002/58/EC, you have the option of exercising your right to object in connection with the use of information society services by means of automated procedures that use technical specifications.

You also have the right to object, on grounds relating to your particular situation, to processing of personal data concerning you which is carried out for scientific or historical research purposes or statistical purposes pursuant to Art. 89 (1) GDPR.

Your right to object may be restricted to the extent that it is likely to render impossible or seriously impair the realisation of the research or statistical purposes and the restriction is necessary for the fulfilment of the research or statistical purposes.

8. right to revoke the declaration of consent under data protection law

You have the right to revoke your declaration of consent under data protection law at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

9. automated decision-making in individual cases including profiling

You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. This does not apply if the decision

  1. is necessary for the conclusion or fulfilment of a contract between you and the controller,
  2. is authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests; or
  3. with your express consent.

However, these decisions may not be based on special categories of personal data pursuant to Art. 9 para. 1 GDPR, unless Art. 9 para. 2 lit. a or g applies and appropriate measures have been taken to protect the rights and freedoms as well as your legitimate interests.

In the cases referred to in (1) and (3), the data controller shall implement suitable measures to safeguard your rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express your point of view and to contest the decision.

10. right to lodge a complaint with a supervisory authority

Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of personal data relating to you infringes the GDPR.

The supervisory authority with which the complaint has been lodged shall inform the complainant of the status and outcome of the complaint, including the possibility of a judicial remedy pursuant to Art. 78 GDPR.