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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 processing personal data.
In this policy, “we”, “us” and “our” refer to the University of St. Gallen, Executive School of Management, Technology and Law (ES-HSG).
2 Use of your personal data
In this section 2 we 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 processing personal data.
Personal data includes in particular:
- Usage data: 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.
- Enquiry data: We may process information contained in any enquiry you submit to us regarding services, especially when ordering brochures and registering for events (“enquiry data”). The enquiry data may include your salutatory, first name, last name, email address, (mobile) phone number, the event you are interested in, place of residence, city, postcode, country, company and your language. The enquiry data may be processed for the purpose of providing the above mentioned services and for the proper recording of these transactions.
- Notification data: 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.
- Correspondence data: We may process information contained in or relating to any communication that you send to us or which relates to any communication (“correspondence data”). The correspondence data may include the content of the message and the metadata associated with it. Our website generates metadata associated with communications through the website forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping.
The legal basis for processing the aforementioned personal data is your consent and/or our legitimate interests, concerning the latter, in particular with regard to the usage data it refers to the monitoring and improvement of our website and services, and for correspondence data, it refers to the proper management of our website and our business as well as communication with users.
In addition to the specific purposes for which we may process your personal data in accordance with this section 2, we may also process your personal data where such processing is necessary to comply with a legal obligation to which we are subject to, or to protect your vital interests or the vital interests of another natural person.
Please do not submit any other person’s personal data to us, unless we prompt you to do so.
Please do not enter any personal data in the search field of our website.
3 Disclosure of your personal data to third parties
We may disclose your personal data to any member of the University of St.Gallen insofar as reasonably necessary for the purposes stated 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 advisers and other third parties insofar as reasonably necessary for the purposes. In particular we are authorized to the following:
- Usage data: We may disclose usage data to our advertising, analytics and social media providers insofar as it is reasonably necessary to measure and improve the success of our advertising and social media efforts. This personal data may include your 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. Advertising providers include, but not limited to, Facebook, Google Adwords, Google DoubleClick, LinkedIn, AddToAny and Youtube.
- Enquiry data: We may disclose your enquiry data to “Rembrand AG” (https://remx.ch) and any successor, in particular but not limited to the purpose of processing your brochure orders or your registration for an event insofar as reasonably necessary for processing your request.
- Notification data: We may disclose your notification data to “Mailerlite” (https://www.mailerlite.com) and any successor, in particular but not limited a. to provide you with relevant digital information.
The legal basis for the disclosure of the aforementioned personal data is your consent and/or our legitimate interests, concerning the latter, in particular with regard to the usage data, it refers to the monitoring and improvement of our website and services, and for inquiry and notification data, it refers to processing your enquiries.
In we may also disclose your personal data if necessary to comply with a legal obligation to which we are subject to, 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 inform you about the circumstances under which your personal data is transferred to countries outside Switzerland and the European Economic Area (EEA).
Our analytics provider Google Analytics as well as our advertising and social media providers, as listed in section 3, are based in the United States of America. The European Commission has taken an “adequacy decision” with regard to the General Data Protection Regulation. Transmissions to the United States of America are protected by appropriate safeguards, namely the EU-US Privacy Shield framework which was signed by all our analytics, advertising and social media providers. Information on this 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 procedures, to ensure that we comply with our legal obligations regarding the retention and deletion of personal data.
Personal data that we process for any purpose shall not be kept for longer than it is necessary for the respective purpose or purposes.
We will retain your personal data as long as necessary only.
It is not possible for us to specify in advance the period of time for which your personal data will be retained. In such case, 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 if this is necessary to comply with a legal obligation to which we are subject to, or in order to protect your vital interests or the vital interests of another natural person.
We may update this policy from time to time and publish the new version on our website. You should check this page occasionally to ensure you agree with any changes to this policy.
7 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 our summary does not contain all the details. 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;
- the right to data portability;
- the right to complain to a supervisory authority; and
- the right to withdraw consent.
You have the right to receive a confirmation as to whether or not we process your personal data. Where we do so, you have the right to access personal data together with certain additional information. Such additional information include details on the purpose of 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.
Under certain circumstances, you have the right to the erasure of your personal data without undue delay. These circumstances include: personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw your consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; processing is for direct marketing purposes; and the personal data have been processed unlawfully. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: to comply with a legal obligation; or for the establishment, exercise or defense of legal claims.
Under certain 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, however, you require personal data for the establishment, exercise or defense of legal claims; and you have objected to processing, but the verification of that objection is pending. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only process it: with your consent; for the establishment, 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 processing your personal data unless we can demonstrate compelling legitimate grounds for processing which override your interests, rights and freedoms, or the processing is for the establishment, 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 processing 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 a party to 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 third parties.
If you come to the conclusion that our processing of your personal data infringes data protection law, you have a right to lodge a complaint with a supervisory authority responsible for data protection issuer. You may do so in the EU member state of your habitual residence, in 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 data is consent, you have the right to withdraw that consent at any time. Your 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.
8 Data protection officer
Our data protection officer’s contact details are:
Thomas Jordan, lic. iur.
Deputy Secretary General / Legal Assistant
University of St.Gallen (HSG)
CH-9000 St. Gallen
Tel.: +41 71 224 24 21
Fax: +41 71 224 29 14