Data protection
Privacy Policy (Version 1.0 dated 25.05.2018)
General information
The protection of your personal data has a high priority for Studierendenwerk Hamburg A.ö.R. We believe it is important that we provide you with comprehensive information about what personal data is collected when you visit our website and how this data is used.
It is basically possible to use our website without providing any personal data. However, if you wish to use special services provided by Studierendenwerk through our website, your personal data may need to be processed. If your personal data needs to be processed and there is no legal basis for such processing, we will generally ask for your consent.
Personal data, such as name, address, e-mail address or telephone number, will be processed in accordance with the requirements of the General Data Protection Regulation and in compliance with the country-specific privacy policy applicable to data protection. This Privacy Policy serves to inform you about the type, scope and purpose of the personal data processed by us. Furthermore, your rights are explained.
As the controller, Studierendenwerk Hamburg has implemented numerous technical and organisational measures in order to ensure the most complete protection of personal data processed through this website. Nevertheless, some security gaps may occur when transmitting data via the Internet, which means that absolute protection cannot be guaranteed. For this reason, every data subject is free to submit personal data to us by alternative means, for example, by telephone.
Definitions
This Privacy Policy is based on the terminology used by the European legislator when the General Data Protection Regulation (GDPR) was adopted. In order to ensure that this Privacy Policy is easy to understand, we wish to start by explaining the terminology used. Below you will find some examples of the terms which we use both in this Privacy Policy and on our website:
a) Personal data
Personal data means any information relating to an identified or identifiable natural person (‘data subject’); An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
b) Data subject Data subject means any identified or identifiable natural person whose personal data is processed by the controller.
c) Processing Processing means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
d) Restriction of processing Restriction of processing means the marking of stored personal data with the aim of limiting its processing in the future;
e) Profiling Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
f) Pseudonymisation Pseudonymisation means the processing of personal data in such a manner 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 to ensure that the personal data are not attributed to an identified or identifiable natural person.
g) 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. Where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
h) Processor Processor means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
i) Recipient Recipient means a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients.
j) Third party Third party means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data;
k) Consent Consent of the data subject means any freely given, specific, informed and unambiguous indication of the data subject's wishes by which they, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to them;
Name and address of the controller
The controller within the meaning of the General Data Protection Regulation, of other data protection laws of the Member States of the European Union and of other provisions related to data protection is:
Studierendenwerk Hamburg AöR
Von-Melle-Park 2
20146 Hamburg
Telephone: +49 (40) 41902 - 0
Website: www.studierendenwerk-hamburg.de
E-mail: datenschutz(at)studierendenwerk-hamburg.de
Any data subject can contact the Data Protection Officer at datenschutz@studierendenwerk-hamburg.de at any time for any questions or suggestions regarding data protection.
Cookies
The website of Studierendenwerk Hamburg uses cookies. Cookies are text files that are stored in a computer system via an Internet browser.
Many websites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a character string through which website and servers can be assigned to the specific Internet browser in which the cookie was stored. This allows visited websites and servers to differentiate the individual browser of the data subject from other Internet browsers that contain other cookies. A specific Internet browser can be recognised and identified using the unique cookie ID.
Thanks to the use of cookies, Studierendenwerk can provide the users of this website with more user-friendly services that would not be possible without the cookie setting. By means of a cookie, the information and offers on our website can be optimised with the user in mind. Cookies allow us, as previously mentioned, to recognise our website users. The purpose of this recognition is to make it easier for users to utilise our website. For example, a website user who uses cookies does not have to enter access data each time the website is accessed, because this is done by the website and the cookie stored on the user's computer system.
The data subject may, at any time, prevent the setting of cookies by our website by using the corresponding settings of the Internet browser they use, and may thus permanently object to the setting of cookies. Furthermore, cookies which have already been set may be deleted at any time using an Internet browser or other software. This is possible in all popular Internet browsers. If the data subject deactivates the setting of cookies in the Internet browser they use, not all functions of our website may be entirely usable.
Collection of general data and information
The website of Studierendenwerk Hamburg collects a series of general data and information whenever a data subject or automated system calls up the website. This general data and information is stored in the server log files. The following may be collected:
1. the browser types and versions used,
2. the operating system used by the accessing system,
3. the website from which an accessing system reaches our website (so-called referrers),
4. the sub-websites which are accessed via an accessing system on our website,
5. the date and time of access to the website,
6. an Internet protocol address (IP address),
7. the Internet service provider of the accessing system,
8. any other similar data and information that may be used in the event of attacks on our information technology systems.
When using this general data and information, Studierendenwerk Hamburg does not draw any conclusions about the data subject. In fact, this information is needed to:
1. deliver the content of our website correctly,
2. optimise the content of our website as well as its advertisement,
3. ensure the long-term viability of our information technology systems and website technology, and
4. provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack.
Therefore, Studierendenwerk analyses anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our company, and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files is stored separately from all personal data provided by a data subject.
Registration function
The data subject has the possibility to register on the website of the controller, which requires personal data to be provided. The type of personal data that is transmitted to the controller is determined by the respective input mask used for the registration. The personal data entered by the data subject is collected and stored exclusively for internal use by the controller, and for its own purposes. The controller may request transfer to one or more processors that also use personal data for an internal purpose which is attributable to the controller.
In addition, during registration on the website of the controller, the IP address assigned to the data subject by the Internet service provider (ISP) as well as the date and time of the registration are stored. The storage of this data is the only way to prevent the misuse of our services, and, if necessary, to make it possible to investigate committed offences. In this respect, the storage of this data is necessary to protect the interests of the controller. This data is not transferred to third parties unless there is a statutory obligation to transfer the data, or if the transfer serves the aim of criminal prosecution. Nor is any of this information matched to any information that may be collected by other components of our website.
The registration of the data subject, whereby their personal data is provided on a voluntary basis, is intended to enable the controller to offer the data subject contents or services that may only be offered to registered users due to the nature of the matter in question. Furthermore, the registration of the data subject serves the purposes of monitoring as well as of own documentation purposes. Registered persons are free to change the personal data provided during the registration at any time, or to have it completely erased from the database of the controller.
The controller shall, at any time, provide information upon request to each data subject as to what personal data is stored about the data subject. In addition, the controller shall rectify or erase personal data at the request or indication of the data subject, insofar as no statutory storage obligations apply to such data. For this purpose, the data subject may contact the Data Protection Officer or any of the controller’s employees.
Contacting us
Studierendenwerk Hamburg offers you the possibility of getting in touch with the controller via e-mail and/or via a contact form. If it is possible to enter personal or business data (e-mail addresses, names, addresses) on our website, any such information is provided on a voluntary basis. In this case, the information provided by the data subject will be stored for the purpose of processing their enquiry. Unless the data is necessary for reasons related to business processing, the data subject may withdraw their previously granted consent to the storage of their personal data, with immediate effect, by contacting us in writing, by e-mail or by fax. The data is not transferred to third parties, unless such a transfer is required by statutory provisions. Nor is any of this information matched to any information that may be collected by other components of our website.
Integration of third-party providers
Use of Google Analytics with anonymisation function
The controller uses Google Analytics on its website, a web analytics service provided by Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043 USA, hereinafter: "Google". Google Analytics uses so-called "cookies” - text files that are stored on your computer and thus allow an analysis of your use of the website.
The information generated by these cookies, such as the time, location and frequency of your website visits, including your IP address, is transmitted to Google in the United States and stored there.
On its website, Studierendenwerk uses Google Analytics with an IP anonymisation function. In this case, the IP address of the data subject is truncated and thereby anonymised by Google already within the Member States of the European Union or in other states which are party to the Agreement on the European Economic Area.
Google will use this information to evaluate your use of our website, to compile reports on website activity for us, and to provide other services related to website activity and internet usage. Google may also transfer this information to third parties if required by law or if third parties process this data on behalf of Google.
Google assures that it does not link your IP address to any other data held by Google under any circumstances. You can disable the installation of cookies by using appropriate settings of your browser software; however, we advise you that in this case you may not be able to fully use all functions of our website.
Google also offers an opt-out option for the most popular browsers, giving you more control over what data Google collects and processes. If you enable this option, website visit information will not be transmitted to Google Analytics. However, enabling this option does not prevent information from being transmitted to us or any other web analytics services we may use. For more information about Google's opt-out option and on how to enable this option, please visit the following link: https://tools.google.com/dlpage/gaoptout
The use of Google Maps with recommendation components
The controller uses the “Google Maps” component on its website in combination with the so-called “Share function". “Google Maps” is a service of Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043 USA, hereinafter “Google.”
Google sets a cookie in order to process the user configuration and data when a website with the integrated “Google Maps” component is displayed. As a general rule, this cookie is not deleted after the browser is closed, but it expires after a certain time, unless you manually delete it prior to its expiry.
If you do not agree with this processing of your data, you may choose to deactivate the “Google Maps” service and, by doing so, prevent the data from being transferred to Google. To do this, you must deactivate the Java Script function in your browser. However, we advise you that in this case you will not be able to use “Google Maps” or might only be able to use it to a limited extent.
The use of “Google Maps” and of the information obtained by “Google Maps” is subject to the Google Terms of Service https://policies.google.com/privacy?hl=en
as well as the Additional Terms of Service for "Google Maps" https://www.google.com/help/terms_maps/.
Use of reCAPTCHA
In order to protect input forms on its website, Studierendenwerk Hamburg uses the "reCAPTCHA” service provided by Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043 USA, hereinafter: "Google". The use of this service allows us to determine whether the corresponding input is made by a human user or whether it is misused by automated machine processing.
To the knowledge of Studierendenwerk Hamburg, the referrer URL, the IP address, the behaviour of the website visitors, information about the operating system, browser and the duration of their website visit, cookies, presentation instructions and scripts, the input behaviour of the user and their mouse movements in the "reCAPTCHA" checkbox are transferred to "Google".
Among other things, Google uses this information to digitise books and other print products, as well as to optimise services such as Google Street View and Google Maps (e.g. house number and street name recognition).
The IP address submitted as part of "reCAPTCHA" will not be amalgamated with any other data held by Google, unless you are logged in to your Google Account at the time you use the "reCAPTCHA" plug-in. Should you wish to prevent this transmission and storage of data about you and your behaviour on our website by "Google", you must log out of "Google" before you visit our website or use the reCAPTCHA plug-in.
The use of the information received by the “reCAPTCHA” service is subject to the Google Terms of Service: https://policies.google.com/privacy?hl=en.
Routine erasure/blocking of personal data and the rights of the data subject
Routine erasure and blocking of personal data
The data controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject.
If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data is routinely blocked or erased in accordance with statutory requirements.
Rights of the data subject
a) Right to confirmation Each data subject shall have the right granted by the European legislator to obtain from the controller the confirmation as to whether or not personal data concerning them is being processed. If a data subject wishes to exercise this right to confirmation, they may contact our Data Protection Officer or any other employee of the controller at any time.
b) Right of access Each data subject shall have the right granted by the European legislator to obtain from the controller information about their personal data stored by the controller and to receive a copy of this information, free of charge and at any time. Furthermore, the European directives and regulations grant the data subject access to the following information:
• the purposes of the processing;
• the categories of personal data concerned;
• the recipients or categories of recipients to whom the personal data has been or will be disclosed, in particular recipients in third countries or international organisations;
• where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
• the existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing;
• the existence of the right to lodge a complaint with a supervisory authority;
• where the personal data is not collected from the data subject: any available information as to its source
• the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.
Furthermore, the data subject shall have a right to obtain information as to whether personal data is transferred to a third country or to an international organisation. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer. If a data subject wishes to exercise this right of access, they may contact our Data Protection Officer or any other employee of the controller at any time.
c) Right to rectification Each data subject shall have the right granted by the European legislator to obtain from the controller without undue delay the rectification of inaccurate personal data concerning them. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement. If a data subject wishes to exercise this right to rectification, they may contact the Data Protection Officer by e-mail at datenschutz(at)studierendenwerk-hamburg.de or any other employee of the controller at any time.
d) Right to erasure (Right to be forgotten) Each data subject shall have the right granted by the European legislator to obtain from the controller the erasure of personal data concerning them without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:
• The personal data is no longer necessary in relation to the purposes for which it was collected or otherwise processed.
• The data subject withdraws consent on which the processing is based according to point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing.
• The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR.
• The personal data has been unlawfully processed.
• The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
• The personal data has been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.
If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of their personal data stored by Studierendenwerk Hamburg, they may contact the Data Protection Officer by e-mail at datenschutz(at)studierendenwerk-hamburg.de or any other employee of the controller at any time. The Data Protection Officer of Studierendenwerk Hamburg or another employee will arrange for the request for erasure to be fulfilled without delay. Where Studierendenwerk Hamburg has made personal data public and is obliged pursuant to Article 17(1) to erase the personal data, Studierendenwerk Hamburg, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested erasure by such controllers of any links to, or copy or replication of, this personal data, as far as processing is not required. If the erasure of data is requested, but the controller is still legally obliged to store it, access to the data will be restricted (blocked). The same applies to the withdrawal of consent. The Data Protection Officer of Studierendenwerk Hamburg or another employee will arrange for the necessary steps to be taken in individual cases.
e) Right to restriction of processing Each data subject shall have the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:
• The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
• The processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of its use instead.
• The controller no longer needs the personal data for the purposes of the processing, but it is required by the data subject for the establishment, exercise or defence of legal claims.
• The data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.
If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of their personal data stored by Studierendenwerk Hamburg, they may contact the Data Protection Officer by e-mail at datenschutz(at)studierendenwerk-hamburg.de or any other employee of the controller at any time. The Data Protection Officer of Studierendenwerk Hamburg or another employee will arrange for the processing to be restricted.
f) Right to data portability Each data subject shall have the right granted by the European legislator, to receive the personal data concerning them, which they have provided to a controller, in a structured, commonly used and machine-readable format. They shall have the right to transmit this data to another controller without hindrance from the controller to which the personal data has been provided, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller. Furthermore, in exercising their right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.
To assert the right to data portability, the data subject may contact the Data Protection Officer by e-mail at datenschutz(at)studierendenwerk-hamburg.de or a staff member at any time.
g) Right to object Each data subject shall have the right granted by the European legislator to object, on grounds relating to their particular situation, at any time, to processing of personal data concerning them, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions. Studierendenwerk Hamburg shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or the processing serves the establishment, exercise or defence of legal claims. We inform you that the withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
If Studierendenwerk Hamburg processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning them for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to Studierendenwerk Hamburg carrying out processing for direct marketing purposes, Studierendenwerk Hamburg will no longer process the personal data for these purposes.
In addition, the data subject has the right, on grounds relating to their particular situation, to object to processing of personal data concerning them by Studierendenwerk Hamburg for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
To assert the right to object, the data subject may contact the Data Protection Officer by e-mail at datenschutz(at)studierendenwerk-hamburg.de or a staff member at any time. In addition, the data subject is free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to exercise their right to object by automated means using technical specifications.
h) Automated individual decision-making, including profiling Each data subject shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning them, or similarly significantly affects them, unless such a decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a controller, or (2) is authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, or (3) is based on the data subject's explicit consent.
If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a controller, or (2) it is based on the data subject's explicit consent, Studierendenwerk Hamburg shall implement suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express their point of view and contest the decision. If a data subject wishes to exercise these rights concerning automated decision making, they may contact the Data Protection Officer by e-mail at datenschutz(at)studierendenwerk-hamburg.de or an employee of the controller at any time.
i) Right to withdraw consent under data protection law Each data subject shall have the right granted by the European legislator to withdraw their consent to processing of their personal data at any time. If a data subject wishes to exercise this right to withdraw consent, they may contact the Data Protection Officer by e-mail at datenschutz(at)studierendenwerk-hamburg.de or an employee of the controller at any time.
j) Right to lodge a complaint Pursuant to Article 77 of the GDPR in conjunction with Section 19 of the New Federal Data Protection Act [BDSG-new], the data subject may lodge a complaint with a data protection supervisory authority. The supervisory authority responsible for us is:
The Hamburg Commissioner for Data Protection and Freedom of Information
Klosterwall 6 (Block C)
20095 Hamburg
Tel: (040) 4 28 54 - 40 40
Fax: (040) 4 279 - 11811
E-mail: mailbox(at)datenschutz.hamburg.de
Internet: https://www.datenschutz-hamburg.de/
Following the office being moved on 5 June 2018:
Kurt-Schumacher-Allee 4
20097 Hamburg, 6th Floor
Changes to this Privacy Policy
The controller reserves the right to change this Privacy Policy. You will be informed of such changes by a corresponding notice.