This privacy statement informs you about the type, scope and purpose of the processing of personal data (hereinafter referred to as "data") within our online services and the websites, functions and contents connected with it, as well as external online sites, such as our social media profiles (hereinafter collectively referred to as "online services"). With regard to the terms used, such as "processing" or "controller", we refer to the definitions in Art. 4 of the General Data Protection Regulation (GDPR).
Types of data processed:
- Inventory data (e.g., names, addresses).
- Contact details (e.g., email, phone numbers).
- Content data (e.g., text input, photographs, videos).
- Usage data (e.g., websites visited, interest in content, access times).
- Meta/communication data (e.g., device information, IP addresses).
Categories of persons concerned
Visitors and users of the online offer (hereinafter we also refer to the persons concerned collectively as "users").
Purpose of the processing
- Providing the online offer, its functions and contents.
- Response to contact requests and communication with users by the zfh and the cooperating universities of applied sciences.
- Security measures.
- Measurement of reach/marketing
- Forwarding of contact data to the cooperating universities of applied sciences within the scope of the management of prospective students
"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.
"Processing" means any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is broad and covers virtually any handling of data.
"Pseudonymisation" means the processing of personal data in such a way that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures which ensure that the personal data are not attributed to an identified or identifiable natural person.
"Profiling" means any automated processing of personal data which consists in using such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects relating to that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or change of location.
"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.
"Processor" means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
Relevant legal basis
We shall take appropriate technical and organisational measures to ensure a level of protection appropriate to the risk in accordance with Article 32 of the GDPR, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of the processing, as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons.
The measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as the access, input, transfer, assurance of availability and separation of the data. We also have procedures in place to ensure the exercise of data subjects' rights, deletion of data and response to data compromise. Furthermore, we already take the protection of personal data into account in the development and selection of hardware, software and procedures, in accordance with the principle of data protection through technology design and through data protection-friendly default settings (Art. 25 GDPR).
Cooperation with processors and third parties
If, in the course of our processing, we disclose data to other persons and companies ( processors or third parties), transmit it to them or otherwise grant them access to the data, this will only be done on the basis of a legal permission (e.g. if a transmission of the data to third parties, such as to payment service providers, is necessary for the performance of the contract pursuant to Art. 6 (1) lit. b GDPR), you have consented, a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).
If we commission third parties with the processing of data on the basis of a so-called "order processing agreement", this is done on the basis of Art. 28 GDPR.
Transfers to third countries
If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if this is done in the context of using third-party services or disclosing or transferring data to third parties, this is only done if it is done in order to fulfil our (pre-)contractual obligations, on the basis of your consent, due to a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we only process or allow the processing of data in a third country if the special requirements of Art. 44 ff. GDPR are met. This means that the processing is carried out, for example, on the basis of special guarantees, such as the officially recognised determination of a level of data protection corresponding to that of the EU (e.g. for the USA through the "Privacy Shield") or compliance with officially recognised special contractual obligations (so-called "standard contractual clauses").
Rights of the data subjects
You have the right to request confirmation as to whether data in question is being processed and to information about this data, as well as further information and a copy of the data in accordance with Art. 15 GDPR.
In accordance with Art. 16 GDPR, you have the right to request that the data concerning you be completed or that the incorrect data concerning you be corrected.
In accordance with Article 17 of the GDPR, you have the right to demand that the data concerned be deleted without delay or, alternatively, to demand restriction of the processing of the data in accordance with Article 18 of the GDPR.
You have the right to request to receive the data concerning you that you have provided to us in accordance with Article 20 of the GDPR and to request that it be transferred to other persons in charge.
You also have the right to lodge a complaint with the supervisory authority concerned in accordance with Article 77 of the GDPR.
Right of revocation
You have the right to revoke consent granted in accordance with Art. 7 (3) GDPR with effect for the future.
Right of objection
You may object to the future processing of data concerning you in accordance with Art. 21 GDPR at any time. The objection can be made in particular against processing for direct advertising purposes.
Cookies and right to object to direct advertising
"Cookies" are small files that are stored on users' computers. Different information can be stored within the cookies. A cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or after his or her visit to an online offer. Temporary cookies, or "session cookies" or "transient cookies", are cookies that are deleted after a user leaves an online offer and closes his or her browser. In such a cookie, for example, the contents of a shopping basket in an online shop or a login status can be stored. Cookies that remain stored even after the browser is closed are referred to as "permanent" or "persistent". For example, the login status can be stored if users visit them after several days. Likewise, the interests of users can be stored in such a cookie, which is used for range measurement or marketing purposes. "Third-party cookies" are cookies that are offered by providers other than the responsible party that operates the online offer (otherwise, if they are only the cookies of the responsible party, they are referred to as "first-party cookies").
If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.
The data processed by us will be deleted or restricted in its processing in accordance with Articles 17 and 18 GDPR. Unless expressly stated within the scope of this data protection declaration, the data stored by us will be deleted as soon as it is no longer required for its intended purpose and the deletion does not conflict with any legal storage obligations. If the data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted. I.e. the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law.
In accordance with legal requirements in Germany, storage is in particular for 10 years in accordance with §§ 147 para. 1 AO, 257 para. 1 nos. 1 and 4, para. 4 HGB (books, records, management reports, accounting vouchers, commercial books, documents relevant for taxation, etc.) and 6 years in accordance with § 257 para. 1 nos. 2 and 3, para. 4 HGB (commercial letters).
According to legal requirements in Austria, storage is carried out in particular for 7 years pursuant to § 132 para. 1 BAO (accounting records, vouchers/invoices, accounts, receipts, business papers, statement of income and expenditure, etc.), for 22 years in connection with real property and for 10 years for records in connection with electronically provided services, telecommunications, radio and television services provided to non-entrepreneurs in EU member states and for which the Mini-One-Stop-Shop (MOSS) is claimed.
Administration, financial accounting, office organisation, contact management
We process data in the context of administrative tasks as well as organisation of our operations, financial accounting and compliance with legal obligations, such as archiving. In doing so, we process the same data that we process in the context of providing our contractual services. The processing bases are Art. 6 para. 1 lit. c. GDPR, Art. 6 para. 1 lit. f. GDPA. Customers, interested parties, business partners and website visitors are affected by the processing. The purpose and our interest in the processing lies in the administration, financial accounting, office organisation, archiving of data, i.e. tasks that serve the maintenance of our business activities, performance of our tasks and provision of our services. The deletion of data with regard to contractual services and contractual communication corresponds to the information provided in these processing activities.
We disclose or transmit data to the tax authorities, advisors such as tax advisors or auditors as well as other fee offices and payment service providers.
Furthermore, we store information on suppliers, organisers and other business partners on the basis of our business interests, e.g. for the purpose of contacting them at a later date. This data, most of which is company-related, is stored permanently.
Business analyses and market research
In order to operate our business economically, to be able to recognise market trends, wishes of the contractual partners and users, we analyse the data we have on business transactions, contracts, enquiries, etc.. In doing so, we process inventory data, communication data, contract data, payment data, usage data, metadata on the basis of Art. 6 para. 1 lit. f. GDPR, whereby the data subjects include contractual partners, interested parties, customers, visitors and users of our online offer.
The analyses are carried out for the purpose of business evaluations, marketing and market research. In doing so, we may take into account the profiles of registered users with information, e.g. on the services they have used. The analyses serve us to increase user-friendliness, to optimise our offer and to improve business management. The analyses serve us alone and are not disclosed externally, unless they are anonymous analyses with summarised values.
If these analyses or profiles are personal, they will be deleted or anonymised upon termination of the users, otherwise after two years from the conclusion of the contract. If possible, the macroeconomic analyses and general tendency determinations will be made anonymously.
Data protection information in the application procedure
We only process the applicant data for the purpose of and within the scope of the application procedure in accordance with the legal requirements. Applicant data is processed to fulfil our (pre)contractual obligations within the scope of the application procedure in accordance with Art. 6 (1) lit. b. GDPR GDPR insofar as the data processing becomes necessary for us, e.g. within the scope of legal procedures (in Germany, § 26 BDSG also applies).
The application procedure requires that applicants provide us with the applicant data. The necessary applicant data is marked if we offer an online form, otherwise it results from the job descriptions, and basically includes personal details, postal and contact addresses and the documents belonging to the application, such as cover letter, CV and certificates. In addition, applicants can voluntarily provide us with additional information.
Insofar as special categories of personal data as defined in Art. 9 (1) GDPR are voluntarily disclosed within the scope of the application procedure, their processing is additionally carried out in accordance with Art. 9 (2) lit. b GDPR (e.g. health data, such as severely disabled status or ethnic origin). Insofar as special categories of personal data as defined in Art. 9 (1) GDPR are requested from applicants as part of the application process, their processing is additionally carried out in accordance with Art. 9 (2) a GDPR (e.g. health data if this is necessary for the exercise of the profession).
If provided, applicants can submit their applications to us using an online form on our website. The data is transmitted to us in encrypted form in accordance with the state of the art. Applicants can also send us their applications by e-mail. Please note, however, that e-mails are generally not sent in encrypted form and applicants must ensure that they are encrypted themselves. We cannot therefore accept any responsibility for the transmission path of the application between the sender and receipt on our server and therefore recommend rather using an online form or sending by post. Instead of applying via the online form and e-mail, applicants still have the option of sending us the application by post.
The data provided by applicants may, in the event of a successful application, be further processed by us for the purposes of the employment relationship. Otherwise, if the application for a vacancy is unsuccessful, the applicants' data will be deleted. Applicants' data will also be deleted if an application is withdrawn, which applicants are entitled to do at any time.
Deletion takes place after the expiry of a period of six months, unless the applicant has a justified revocation, so that we can answer any follow-up questions about the application and meet our obligations to provide evidence under the Equal Treatment Act. Invoices for any reimbursement of travel expenses will be archived in accordance with tax law requirements.
Users can create a user account. As part of the registration process, the required mandatory information is provided to the users and processed on the basis of Art. 6 (1) lit. b GDPR for the purpose of providing the user account. The processed data includes in particular the login information (name, password and an e-mail address). The data entered during registration is used for the purposes of using the user account and its purpose.
Users may be informed of information relevant to their user account, such as technical changes, by e-mail. If users have terminated their user account, their data relating to the user account will be deleted, unless there is a legal obligation to retain it. It is the responsibility of the users to save their data in the event of termination before the end of the contract. We are entitled to irretrievably delete all user data stored during the term of the contract.
Within the scope of the use of our registration and login functions as well as the use of the user account, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests as well as those of the users in protection against misuse and other unauthorised use. As a matter of principle, this data is not passed on to third parties unless it is necessary for the pursuit of our claims or there is a legal obligation to do so in accordance with Art. 6 Para. 1 lit. c GDPR. The IP addresses are anonymised or deleted after 7 days at the latest.
Comments and contributions
When users leave comments or other contributions, their IP addresses may be stored for 7 days due to our legitimate interests as defined in Art. 6 (1) lit. f. GDPR. This is done for our security in case someone leaves unlawful content in comments and posts (insults, prohibited political propaganda, etc.). In this case, we ourselves can be prosecuted for the comment or post and are therefore interested in the identity of the author.
Furthermore, we reserve the right, due to our legitimate interests pursuant to Art. 6 para. 1 lit. f. GDPR, to process the user's data for the purpose of spam detection.
The data provided as part of the comments and contributions will be permanently stored by us until the user objects.
Details of the user when contacting us
When contacting us (e.g. by contact form, e-mail, telephone or via social media), the user's details are processed for the purpose of handling the contact request and its processing pursuant to Art. 6 (1) lit. b) GDPR. The user's details may be stored in a customer relationship management system ("CRM system") or comparable enquiry organisation.
We delete the requests if they are no longer necessary. We review the necessity every two years; furthermore, the legal archiving obligations apply.
With the following information, we inform you about the contents of our newsletter as well as the registration, dispatch and statistical evaluation procedure and your rights of objection. By subscribing to our newsletter, you agree to receive it and to the procedures described.
Content of the newsletter: We send newsletters, e-mails and other electronic notifications with promotional information (hereinafter "newsletter") only with the consent of the recipients or a legal permission. If the contents of the Newsletter are specifically described in the course of registration, they are decisive for the consent of the user. Apart from that, our newsletters contain information about our services and us.
Double opt-in and logging: Registration for our newsletter takes place in a so-called double opt-in process. This means that after registration you will receive an e-mail in which you are asked to confirm your registration. This confirmation is necessary so that no one can register with other email addresses. The registrations for the newsletter are logged in order to be able to prove the registration process in accordance with the legal requirements. This includes the storage of the registration and confirmation time as well as the IP address. Changes to your data stored with the dispatch service provider are also logged.
Registration data: To register for the newsletter, it is sufficient to enter your e-mail address. Optionally, we ask you to enter a name for the purpose of a personal address in the newsletter.
The newsletter is sent and the associated performance measurement is carried out on the basis of the recipients' consent pursuant to Art. 6 para. 1 lit. a, Art. 7 GDPR in conjunction with § 7 para. 2 no. 3 UWG or, if consent is not required, on the basis of our legitimate interests in direct marketing pursuant to Art. 6 para. 1 lt. f. GDPR in conjunction with § 7 para. 3 UWG.
The logging of the registration process takes place on the basis of our legitimate interests pursuant to Art. 6 para. 1 lit. f GDPR. Our interest is in the use of a user-friendly and secure newsletter system that serves our business interests as well as the expectations of the users and also allows us to prove consent.
Cancellation/revocation - You can cancel receipt of our newsletter at any time, i.e. revoke your consent. You will find a link to cancel the newsletter at the end of each newsletter. We may store unsubscribed email addresses for up to three years based on our legitimate interests before deleting them in order to be able to prove consent previously given. The processing of this data is limited to the purpose of a possible defence against claims. An individual deletion request is possible at any time, provided that the former existence of consent is confirmed at the same time.
Newsletter - CleverReach
The newsletter is sent using the dispatch service provider CleverReach GmbH & Co. KG, Mühlenstr. 43, 26180 Rastede, Germany. You can view the data protection provisions of the dispatch service provider here:
https://www.cleverreach.com/de/datenschutz/. The dispatch service provider is used due to our legitimate interests according to Art. 6 para. 1 lit. f GDPR and an order processing agreement according to Art. 28 para. 3 p. 1 GDPR.
The dispatch service provider may use the recipients' data in pseudonymous form, i.e. without assigning it to a user, to optimise or improve its own services, e.g. to technically optimise the dispatch and presentation of the newsletter or for statistical purposes. However, the dispatch service provider does not use the data of our newsletter recipients to write to them itself or to pass the data on to third parties.
Google is certified under the Privacy Shield agreement and thereby guarantees compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
Google will use this information on our behalf for the purpose of evaluating the users' use of our website, compiling reports on the activities undertaken within the website and providing us with other services relating to the use of this website and the internet. In doing so, pseudonymous user profiles of the users can be created from the processed data.
We only use Google Analytics with IP anonymisation activated. This means that the IP address of the user is shortened by Google within member states of the European Union or in other contracting states of 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.
The IP address transmitted by the user's browser will not be merged with other data from Google. Users can prevent the storage of cookies by setting their browser software accordingly; users can also prevent the collection of the data generated by the cookie and related to their use of the online offer to Google as well as the processing of this data by Google by downloading and installing the browser plugin available at the following link: http://tools.google.com/dlpage/gaoptout?hl=de.
The users' personal data is deleted or anonymised after 14 months.
Google AdWords and conversion measurement
Due to our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offer in accordance with Art. 6 Para. 1 lit. f. GDPR), we use the services of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, ("Google").
Google is certified under the Privacy Shield agreement and thereby offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
We use the online marketing method Google "AdWords" to place ads in the Google advertising network (e.g. in search results, in videos, on web pages, etc.) so that they are displayed to users who have a presumed interest in the ads. This allows us to better target ads for and within our online offering to present users only with ads that potentially match their interests. If, for example, a user is shown ads for products he or she has been interested in on other online offers, this is referred to as "remarketing". For these purposes, when our website and other websites on which the Google advertising network is active are called up, a code is executed directly by Google and so-called (re)marketing tags (invisible graphics or codes, also known as "web beacons") are integrated into the website. With their help, an individual cookie, i.e. a small file, is stored on the user's device (comparable technologies can also be used instead of cookies). This file records which web pages the user has visited, which content the user is interested in and which offers the user has clicked on, as well as technical information on the browser and operating system, referring web pages, time of visit and other information on the use of the online offer.
Furthermore, we receive an individual "conversion cookie". The information obtained with the help of the cookie is used by Google to create conversion statistics for us. However, we only learn the anonymous total number of users who clicked on our ad and were redirected to a page tagged with a conversion tracking tag. However, we do not receive any information with which users can be personally identified.
User data is processed pseudonymously within the Google advertising network. This means that Google does not store and process the name or email address of the user, for example, but processes the relevant data on a cookie basis within pseudonymous user profiles. This means that from Google's perspective, the ads are not managed and displayed for a specifically identified person, but for the cookie holder, regardless of who this cookie holder is. This does not apply if a user has expressly allowed Google to process the data without this pseudonymisation. The information collected about users is transmitted to Google and stored on Google's servers in the USA.
Online presence in social media
We have an online presence within social networks and platforms in order to be able to communicate with the customers, interested parties and users active there and to inform them about our services. When calling up the respective networks and platforms, the terms and conditions and data processing guidelines of their respective operators apply.
Integration of third-party services and content
We use content or service offers from third-party providers within our online offer in order to integrate their content and services, such as videos or fonts (hereinafter uniformly referred to as "content"). This is done due to our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offer in accordance with Art. 6 Para. 1 lit. f. GDPR)
This always requires that the third-party providers of this content perceive the IP addresses of the users, as without the IP address they would not be able to send the content to their browsers. The IP address is therefore necessary for the display of this content. We endeavour to use only such content for which the respective providers use the IP address only for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. The "pixel tags" can be used to evaluate 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, time of visit and other information about the use of our online offering, as well as being linked to such information from other sources.
Typekit fonts from Adobe
We use external "Typekit" fonts from the provider Adobe Systems Software Ireland Limited, 4-6 Riverwalk, Citywest Business Campus, Dublin 24, Republic of Ireland. This is done due to our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offer in accordance with Art. 6 para. 1 lit. f. GDPR). Adobe is certified under the Privacy Shield agreement and thereby offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000TNo9AAG&status=Active).