(1) At Digital Education Holdings Limited, Villa Bighi, Chaplain‘s House, Triq il-Marina, Kalkara, KKR 1320, Malta, phone +356 2169 5955, e-mail email@example.com (hereinafter “we” or “EDU”), we are committed to protecting the privacy of your personal data. This document sets out what data will be collected, processed and used in connection with the online programme entitled “Award in Foundations of Precision Medicine” for educational practitioners to learn online in the English language (hereinafter “Programme”) as a service on the healthyageing.edu.edu.mt, precisionmedicine.edu.edu.mt website and subsites (hereinafter: “Service”).
(2) We take the protection of personal data very seriously, and comply strictly with the rules of data protection law, in particular the German Federal Data Protection Act (hereinafter “BDSG”) and the General Data Protection Regulation (hereinafter “GDPR”). Our service will only collect personal data to the extent to which this is technically or contractually required or if the User has given their expressed consent.
(3) The Service comprises courses based on innovative online learning and teaching methods, which are open to registered learners from around the world (hereinafter: “Users”). The program is aimed at developing and implementing new forms of scientific, collaborative problem-solving methods and facilitating the peer-review of findings. To enable Users to participate in the Programme offered by the Service, EDU provides a collaborative platform with various work and communication functions (forums, blogs, message services and contact buttons). It is important to us that Users can at all times trust in EDU complying with data privacy, and that Users know which personal data EDU will collect during a visit to the Service, and how EDU processes, uses and transmits these data. The following explanations serve to provide you with information in this respect. Furthermore, we would like to make you familiar with the security measures which we have taken in order to protect your personal data from manipulation, loss, destruction and improper use.
§ 1 Controller
(1) In accordance with Art. 4 Nr. 7 of the GDPR, the controller is
Digital Education Holdings Limited,
Villa Bighi, Chaplain‘s House, Triq il-Marina, Kalkara, KKR 1320, Malta
Telephone: +356 222 631 21
Registration Number C 82123
You can reach our data protection officer via firstname.lastname@example.org or by written mail to our address with the addition “Data Protection Officer”.
§ 2 Data Processing Activities when visiting our websites
(1) If you use our websites for informational purposes only, e.g. if you do not register or otherwise provide us with information, we only collect the personal data that your browser transmits to our server. If you wish to view our websites, we collect the following data, which are technically necessary in order for us to display our websites to you and to guarantee stability and security:
– Date and time of the request,
– Time zone difference to Greenwich Mean Time (GMT),
– Content of the request (specific site/page),
– Access status/HTTP-status code,
– Respective data amount transferred,
– Website that the request is coming from,
– Server Log Files,
– Operating system and its interface
– Language and version of the browser software.
(2) The legal basis is Art. 6 Para. 1 Sent. 1 lit. f. GDPR and the data are saved only for the duration of your visit.
§ 3 Data Processing Activities when you contact us
When you contact us via E-mail, telephone or a contact form, we process the data you provide (e.g. e-mail address, name and/or telephone number) in order to respond to your questions or to process your requests. The consent you give in the course of contacting us provides the legal basis for such data processing activities (Art. 6 Para. 1 lit. b) GDPR).
§ 4 Data Processing with regard to profile data
(1) The User may enroll with the Service with his email address or with his existing social network profile. Once the User enrolls with the Service and sets up a user account, we will process the following personal data:
- First Name
- Last Name
- Date of Birth
- Country of residence
- Educational Background
- Career Level
- Prior Course Participation
- Invoicing Details, as needed to provide you a valid VAT invoice
(2) These details are mandatory and required to create a User profile, check eligibility and overall successfully register learners for the education programme. Information like the name, country, occupation, industry and company will be added to the User profile and can be viewed by other Users. If a User is member of a team their e-mail-address may be disclosed to a limited number of other team members (max. 6 persons) in accordance with the chosen profile settings. The User can also add/upload the following details to the profile:
- Industry of employment (Construction, Education, Manufacturing, etc.)
- A brief introduction or bio
This information is optional. The user decides which personal information they wish to disclose to other Users. Should the User choose not to enter any information or upload a photograph the respective fields in the profile will not be displayed.
(3) Should the User wish to receive a certificate on the successful completion of an online course (incl. credit point) the following data will be collected:
- Full name
- Certificate request
- Date of birth
- Place of birth
- A certified English copy of the highest academic degree received (needed only for ECTS-point bearing courses)
- A certified English copy of a recognized identification card or passport received (needed only for ECTS-point bearing courses)
This information is required to issue certificates. This data cannot be viewed by other Users.
(4) The User can access and change the profile data at any time. They are only used for the purpose of creating and managing the profile as well as implementing and providing the online courses offered by the Service as well as to monitor learning success and carry out research projects and internal quality assurance measures. When registering, the User must accept the terms of this privacy notice by ticking the relevant box. (5) The existing contractual relationship constitutes the legal basis for the processing (Art. 6 Para. 1 Sent. 1 lit. b. GDPR).
§ 5 Data Processing Activities during the performance of contract
(1) If you register with us, we process your master and contact data as well as your communication, access and contract data in order to fulfil and process the contractual services. For the aforementioned purpose, your data may be transferred to service providers who support us with our business and who we have of course selected with the utmost care and diligence. Such service providers include, in particular, providers of technical services who support us in rendering our services. In particular, this data may be shared with PRECISION MEDICINE ALLIANCE GmbH (Jens-Jacob-Eschel-Straße 17, 25938 Nieblum auf Föhr, Germany) and XPOMET Innovation in Medicine GmbH (Tucholskystraße 13; D-10117 Berlin).
(2) The existing contractual relationship constitutes the legal basis (Art. 6 Para. 1 Sent. 1 lit. b. GDPR).
§ 6 Usage data, statistical analyses
(1) If, as a participant of the Service, the User takes part in its Programme, EDU will collect and store data about the Users learning habits as well as communication data generated between the User and the other Users (e.g. tests, questions and answers). This data and content will be used exclusively to conduct the online programme, including the platform functionalities provided, as well as to monitor learning success and carry out research projects and internal quality assurance measures.
(2) In addition, User statistics will be compiled to make it possible to track participants’ activities in general, to eliminate errors and to adapt and improve the existing online programme where necessary. A corresponding role concept exists for carrying out the statistical analyses. According to this, all analytics are anonymous and not specific to a particular individual. Moreover, they may only be generated and used by the respective programme instructors, programme supervisors and organizers as well as administrators.
(3) The legal basis is Art. 6 Para. 1 Sent. 1 lit. f GDPR – our legitimate interests to improve our service.
§ 7 Forums, blogs, messaging services and contact buttons
The online platform of the Service allows Users to exchange information with teaching staff, speakers, mentors and tutors as well as other programme participants via forums, blogs and messaging services. These options are to be used exclusively for communication in connection with the programmes offered by the Service and not for private purposes. Information made available by the User in this regard will be forwarded via the Internet and some of this information can be viewed by all Users. Even using the highest security standards, it is not possible to guarantee absolute protection of information when communicating via the Internet. The User should therefore give careful consideration to what personal information they would like to share with others and should not pass on any confidential information.
(2) The legal basis is the contractual relationship (Art. 6 Para. 1 Sent. 1 lit. b GDPR).
§ 8 Data security
The IT equipment used for the Service is located within the EU/EWR under the scope of the EU Data Protection Directive 95/46/EC and complies with the applicable statutory data protection and data security provisions. All premises and equipment are secured to prevent both unauthorized access and loss of data, and are regularly checked and maintained. Access to the systems is subject to strict requirements and is continuously monitored and logged in such a way that it can be reviewed and verified. Authorized persons receive regular training and are required to comply with the data protection provisions.
§ 9 Cookies
(2) The User can restrict or prevent the use and storage of cookies by changing the corresponding browser settings. In most Internet browsers, this can be done by accessing the cookie settings via the menu at the top of the screen. In this case, it may no longer be possible to access certain parts of the Service, or such access may be very limited.
(3) The legal basis is Art. 6 Para. 1 Sent. 1 lit. f GDPR – our legitimate interests to improve our service.
§ 10 Forwarding data to third parties
(1) Data are only transmitted to third parties in a manner that is in compliance with the applicable statutory provisions. We only transmit user data to third parties if, for example, doing so is necessary for contractual purposes pursuant to Article 6 Para. 1 lit. b. GDPR or on the basis of legitimate interests in economic and effective business operation within the meaning of Art. 6 Para. 1 lit. f. GDPR.
(2) In the event that we employ subcontractors in order to provide our services, we shall take appropriate legal precautions and corresponding technical and organisational measures in order to ensure that your personal Data are protected in accordance with the applicable statutory provisions.
In particular, registration statistics may be shared with PRECISION MEDICINE ALLIANCE GmbH (Jens-Jacob-Eschel-Straße 17, 25938 Nieblum auf Föhr, Germany) and XPOMET Innovation in Medicine GmbH (Tucholskystraße 13; D-10117 Berlin).
(3) In case contents, tools or other means of third parties (hereinafter jointly referred to as “Third Party Providers”) are used in the framework of this privacy statement and the stated registered offices of those Third-Party Providers are situated in a third country, it should be assumed that data are transferred to the countries in which the Third Party Providers have their registered offices. Third countries are to be understood as such countries in which the GDPR does not constitute directly applicable law, i. e. in general countries outside of the EU or the European Economic Area. Data are only transferred to third countries if an adequate level of data protection is ensured, the user has given explicit consent, or the law provides another form permission for such a transfer.
(4) Any other disclosure of User data will only be made within the framework of the statutory information obligations, or upon a judicial decision. In the event of an order issued by a competent body, EDU may, in individual cases, disclose such data, provided that this is necessary for purposes of criminal prosecution, danger prevention activities by the state police authorities, in order to fulfil the statutory tasks of the federal and state offices for the protection of the constitution, the German federal intelligence service, the military counterintelligence agency or the federal criminal office within the framework of its task of preventing the dangers associated with international terrorism or in order to enforce intellectual property rights.
§ 11 Sharing Information with Others
We do not share personal information outside the DEH group except in certain circumstances, including:
· When the data subject allows us to share the information, such as when you:
o elect to share your personal information with third party partners and providers listed on our Sites, so they can send you information, offers and promotions about their products and services;
o choose to share your personal information with third parties or their sites or platforms, such as when you share one of our blog posts to your social media feed;
o publish information publicly on our site – any such personal information shared by you will be available to others who may collect or use it; or
use third-party features on our site.
(Please note that once personal information is shared with another company, the information received by the other company becomes subject to its privacy policies and practices).
· When we cooperate with other companies, such as our partners, to offer joint products and services to you or when such partners sponsor or participate in our events and conferences;
· When our service providers are providing services on our behalf. For example, we may use an outside platform to host all or parts of our sites or to provide certain features of our services related to system performance and reliability, video streaming and delivery and security;
· When we may use a credit card processing company to bill you for services you purchase. Unless otherwise expressly noted, these service providers are prohibited from using the personal information we have shared with them for purposes other than those requested by us or required by law;
· To enforce our terms, agreements, policies or rules, to help protect the security, integrity and availability of our or another party’s products, systems and services;
· To exercise or protect the rights, property (including intellectual property), or safety of DEH, our users, or others;
· To comply with legal requirements; or in other cases if we believe in good faith that disclosure is required by law (including in response to a lawful subpoena or other law enforcement request); and
· In connection with a sale, divesture, or transfer of our company (including any shares in the company) or any combination of its products, services, assets, affiliates, and/or businesses. Your personal information (such as customer names and email addresses, and user information related to the our services) may be among the items sold or otherwise acquired in these types of transactions. We may also sell, assign or otherwise transfer such information in the course of corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions, reorganizations, liquidations, similar transactions or proceedings involving all or a portion of the company. You will be notified via email and/or a prominent notice on our site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
§ 12 Web analysis and other third-party services
(1) The Service uses Google Analytics on its website. Google Analytics makes it possible for website owners to obtain information on the number of visitors to their website, where they come from and their surfing habits while on the site, which can then be used to improve the website concerned. To this end, certain data is transmitted in anonymized form to Google servers in the USA where it is automatically analyzed. The version of Google Analytics used by the Service is programmed in such a way that the last 8 digits of the user’s IP address are deleted even before the data is transmitted to the USA. This makes it impossible for the transmitted data sets to be assigned to a specific User. If the User nevertheless does not want User data to be compiled and analyzed by Google Analytics, they can follow this link http://tools.google.com/dlpage/gaoptout?hl=de and install the deactivation add-on developed by Google.
(2) The Service uses Google+, which is provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States (“Google”). Visiting our website involves a link to the Google server, which creates and integrates a connection to the browser of the website visitor and the website displayed. The plugin transmits the visit of our website to Google. We have no influence on the scope, content or transmission of the data and IP address of the User which Google obtains through the connection. In respect of the use of data which is transmitted to Google, the User can view the guidelines set down by Google on the following website: https://developers.google.com/+/web/buttons-policy. The Service uses so-called social plug-ins of the social network facebook.com (“Facebook”). Facebook is operated by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA. For detailed information on the functions of the various plug-ins and their appearance, please go to the following website: https://developers.facebook.com/docs/plugins
(5) This website uses the services of MailChimp for sending newsletters and the analysis of advertising campaigns. Provider is Rocket Science Group LLC, 675 Ponce De Leon Ave NE, Suite 5000, Atlanta, GA 30308, USA.
MailChimp is a service with which, among other things, the dispatch of newsletters can be organized and analyzed. If you enter data for the purpose of newsletter subscription (e.g. e-mail address), it will be stored on MailChimp’s servers in the USA. MailChimp is certified according to the “EU-US Privacy Shield”. The “Privacy Shield” is an agreement between the European Union (EU) and the USA which is intended to ensure compliance with European data protection standards in the USA.
MailChimp allows us to analyze our advertising campaigns. Among other things, it can be determined whether a message has been opened and which links have been clicked. We also collect technical information (e.g. time of retrieval, IP address, browser type and operating system). This information cannot be assigned to the respective recipient. It is used exclusively for statistical analysis of campaigns. The results of these analyses can be used to better adapt future campaigns to the interests of the recipients.
Data processing is based on your consent (Art. 6 para. 1 lit. a DSGVO) or our legitimate interests (Art. 6 para. 1 lit. f DSGVO) to improve our offers. You can revoke this consent at any time. The legality of the data processing operations that have already taken place remains unaffected by the revocation.
The data stored by you with us for the purpose of newsletter subscription will be stored by us until you unsubscribe from the newsletter and will be deleted both from our servers and from the servers of MailChimp after unsubscribing from the newsletter. Data stored by us for other purposes (e.g. e-mail addresses for the member area) remain unaffected by this.
(6) In order to improve the convenience and quality of our service we use the web services conversion tracking and retargeting technology of Adform ApS, Hovedvagtsgade 6, 1103 Copenhagen K, Denmark. Adform receives and processes the data generated by using the corresponding cookies on our website.
- Conversion tracking: The temporary cookie for conversion tracking is set if a user comes into contact with an ad placed by Adform. Users who do not wish to participate in tracking can deactivate the Adform cookie in their internet browser. You can remove cookies stored on your computer by deleting temporary internet files. Alternatively there is an opt-out offer at Adform: https://site.adform.com/datenschutz-opt-out/
- Retargeting: The temporary cookie makes it possible to target internet users on our partners’ websites who have already shown interest in our website and our products. In retargeting, the integration of the ads is guided by a cookie-based analysis of prior user behaviour.
You can find further information on Adform’s data privacy conditions at https://site.adform.com/privacy-center/overview
We Service use Functional Software, Inc.’s dba Sentry error tracking service on our platform. With this tool we can identify errors on our websites to fix them. For better troubleshooting, only impersonal data such as the operating system, browser version and your IP address will be transmitted.
The EU-U.S. Privacy Shield certification from Functional Software, Inc. dba Sentry can be found at: https://www.privacyshield.gov/participant?id=a2zt0000000TNDzAAO
(11) This Service uses Newrow. Professional Online Learning Platform Boosts Learner Success – newrow_
(12) Analytic tools serve to make your internet experience more user-friendly and effective. The legal basis is Art. 6 Para. 1 Sent. 1 lit. f GDPR – our legitimate interests to improve our service.
§13 Lesson Recordings
(1) In order to continuously improve the student experience, EDU reserves the right to record live classroom sessions. Such recordings may be used for the purpose of providing individualised feedback to students and evaluating the performance of instructors. No such recordings will be used for any commercial purpose and access to these materials will be restricted to authorised personnel only.
(2) Any classroom recording will be deleted or destroyed within 18 months of recording, or at any time upon the explicit written request of an individual appearing in the recording.
(3) The legal basis is Art. 6 Para. 1 Sent. 1 lit. f GDPR – our legitimate interests to improve our service.
§ 14 Other Data Processing Activities
(1) Should you have given your consent to receive our promotions (newsletters, SMS, E-mail, by post, etc.), we shall use your personal data to inform you of our offers via the respective means of communication. You can retract your approval of being approached in a promotional manner at any time. The legal basis is Art. 6 Para. 1 Sent. 1 lit. a GDPR – your consent.
(2) We reserve the right to use your data in order to contact you should our services undergo or have undergone important changes or developments.
§ 15 Your rights
(1) You have the following rights in relation to us with regard to the personal data concerning you:
–Right of access (Art. 15 GDPR),
–Right to rectification and erasure (Art. 16 and 17 GDPR),
–Right to restriction of processing (Art. 18 GDPR),
–Right to object processing (Art. 21 GDPR),
–Right to data portability (Art. 20 GDPR).
(2) Furthermore, you have the right to complain to a supervisory authority for data protection about the processing of your Data by us.
(3) We would like to point out that any possible consent you have given pertaining to data protection can be revoked at any time, effective immediately. The same applies when you have given consent to be approached in a promotional manner. To do so, please contact us informally via e-mail at: email@example.com . Such revocation can result in our services no longer being available at all, or only with restrictions.
§ 16 Data erasure, storage period
(1) The data we store shall be deleted as soon as they are no longer needed for the purpose for which they are being stored and the law does not prescribe a statutory duty for the data to be retained. In the event that user data are not deleted on grounds that they are still required for other or legally admissible reasons, their processing shall be restricted. This means that the data shall be blocked and shall not be processed for other purposes. This applies, for instance, for user data that have to be kept for reasons pertaining to trade or tax law.
(2) In accordance with the pertinent legal provisions, such data shall be stored for 6 years pursuant to Section 257 Para. 1 German Commercial Code (commercial books, inventories, opening balance sheets, annual financial statements, trade letters, accounting records, etc.) and 10 years pursuant to Section 147 Para. 1 of the German Fiscal Code (accounts, records, situation reports, accounting records, trade or business letters, documents relevant for taxation, etc.).
§ 17 Final provisions
(1) We employ technical and organizational security measures to protect the data we have gathered, especially against accidental or deliberate manipulation, loss, destruction or attack by unauthorized persons. Our security measures are subject to continuous improvement in line with technological advances and development.