Privacy Statement
This privacy statement applies to the use of our online offer platform.joinus4health.eu
, in the following referred to as “platform”. We would like to inform you here about the way in which we process your personal data (hereinafter referred to as “data”) and explain the purpose and scope.
Version: 22.11.2023
Table of Content
- Privacy Statement
- Name and contact of the person responsible in accordance with Article 4 Paragraph 7 GDPR
- Safety and protection of your personal data
- Information on the collection of personal data
- Use of Matomo
- Order processors
- Rights of data subjects
- Revocation of consent
- Right to confirmation
- Right to information
- Right to rectification
- Right to erasure (“right to be forgotten”)
- Right to restriction of processing
- Right to data portability
- Right to object
- Automated individual decision-making, including profiling
- Right to lodge a complaint with a supervisory authority
- Right to effective judicial remedy
- Links
- Changes of our data protection regulations
- Definitions and Explanations
Name and contact of the person responsible in accordance with Article 4 Paragraph 7 GDPR
Dr. med. Birgit Schauer
Institute for Community Medicine, Unit of SHIP-KEF
University Medicine Greifswald (UMG)
Walther-Rathenau-Strasse 48
DE-17475 Greifswald, Germany
E-Mail: birgit.schauer [at] uni-greifswald.de
Website: https://www2.medizin.uni-greifswald.de/icm/index.php?id=20
Data protection officer
Prof. Ulf Glende
Data protection officer of the UMG
Walther-Rathenau-Straße 49
DE-17475 Greifswald
Phone: +49 (0)3834 86-5124
E-Mail: datenschutz-umg [at] med.uni-greifswald.de
Safety and protection of your personal data
We consider it our primary responsibility to protect the confidentiality of the personal information you provide and to protect it from unauthorised access. That’s why we take the utmost care and use state-of-the-art security standards to ensure maximum protection of your personal information. As a private company, we are subject to the provisions of the European General Data Protection Regulation (GDPR) and the regulations of the German Federal Data Protection Act (BDSG). We have taken technical and organisational measures which ensure that data protection regulations are observed by us and by our external service providers.
Security Standards
When developing and providing our platform, we already take security aspects into account in advance (Privacy by Design).
The use of our platform is only possible via TLS-encrypted channels. This ensures that third parties cannot extract any content from the transmitted data.
The security-related details of plugins that we use are carefully checked before they are applied.
We do not collect and store unnecessary data (data economy).
If settings are possible for the user, the most privacy-friendly choice is always preselected (privacy by design).
Existence of automated decision-making
We refrain from automatic decision-making or profiling.
Information on the collection of personal data
Below, we inform you of the collection of personal data when using our platform. Personal data is e.g. you name, address, e-mail addresses, user behaviour, etc.
Contact by e-mail
When contacting us by e-mail, the information you provide (e.g. your e-mail address and, if applicable, your name and your telephone number) is stored by us in order to answer your questions (in accordance with Art. 6 (1) (f) GDPR). We delete the data collected in this manner once storage is no longer required, if processing is restricted, or in the event that legal retention obligations exist.
We would like to point out that e-mails are generally transmitted not encrypted – in plain-text. Even though there may be connection encryption, end-to-end encryption is not provided. Therefore, please do not send sensitive data by e-mail. If necessary, please contact us to initiate a secure transmission.
The following data is transmitted when sending e-mails:
- Sender address, which may contain further personal data, such as name or year of birth.
- Information about the route taken by the e-mail
- If applicable, the e-mail client used and its version
- If applicable, operating system used and its version and, if applicable, interface
- References to previous e-mails, if applicable
- E-mail content, which may contain further personal data, if applicable
Use of our platform
Use without registration and login
When you merely use the platform for informational purposes, i.e. if you do not register or otherwise provide information to us, we only collect the personal data that your browser transmits to our server. The technically necessary data that your browser automatically transmits to our server is stored for a maximum of 14 days in so-called server log files. Personal data is not merged with other data sources. We use parts of the data to compile completely anonymous statistics on page usage. If you wish to view our platform, we collect the following data which is technically necessary for us to display our internet presence to you and to ensure its stability and security (here, the legal basis is Article 6 (1) (f) GDPR):
- IP address
- Browser type and browser version
- Operating system used and its version and, if applicable, interface
- Referrer URL (website from which you came to our platform)
- Preferred languages, encoding and MIME types
- Date and time of the request
- Time-zone difference to Greenwich Mean Time (GMT)
- Access status/HTTP status code
- Amount of data transferred in each case
Use with registration or login
If you register on our platform in order to be able to contribute to the project, we will collect the following data with your consent in addition to the above information to enable you to use it (the legal basis is Article 6 (1) (a) GDPR):
- Username (feel free to use a pseudonym)
- Password
- E-mail-address
you can optionally provide further information on the following topics in your profile:
- Main language (DE, EN, NL, PL)
- Additional languages
- Country
- Postal code
- Year of birth
- Gender
- RRI group
- Participation in a study group
- Experience
- Specific interests
A linkage of the anonymous usage data (browser type,…) with the data of your account, does not take place. Your personal data (password, e-mail address) will only be used to ensure the technical function for the use of our platform and will not be passed tho third-parties in any way.
Your username is displayed publicly and can be seen by all other visitors of our platform.
E-mail address
An e-mail address is required from you so that we can confirm your account, inform you about activities in the groups you have chosen and to send you a new password.
Passwords
Passwords are always stored according to the security standards. Before the password is stored in the database, it is changed using mathematical methods so that it cannot be read by us (hashed, salted). This ensures that even in the event of a successful attack, no passwords can fall into the wrong hands.
In general, however, please do not use a password that you use elsewhere.
Optional data and content
If you provide optional data in your profile (country, postal code, gender…), you support us to use this scientifically within the JoinUs4Health project. When we use this data, we will prevent it from being traced back to you, i.e., it will only be made available separately when used, e.g., summary statistics on the first three digits of the zip codes used or on the overall gender ratio, but never statistics on a combination of more than three such pieces of information. We only use the data anonymously or in summary across multiple users (aggregated). The legal basis is Article 6 (1) (a) GDPR.
The same applies to the data that you contribute in the context of the teams (comments, suggestions,…). If it still happens that you are dissatisfied, please feel free to contact us via contact@joinus4health.eu
and we will find a solution.
Translation of content
In order to make our offer accessible to as wide a range of visitors as possible, we reserve the right to have content automatically translated into other languages. This exclusively concerns content of contributions (Art. 6 (1) (f) GDPR).
Cookies, session storage and local storage
Cookies
Cookies are text files that can be a maximum of 4096 bytes in size. The files are stored on your hard disk by the browser you are using. Cookies are assigned to the browser you are using and provide certain information to the entity that sets the cookie. Cookies cannot execute programs or transfer viruses to your computer. They are used to make the website as a whole more user-friendly and effective.
You can configure your browser settings according to your wishes and, for example, refuse the setting of certain or all cookies. However, this may restrict the functionality of websites.
This website may use the following types of first-party cookies:
- technically necessary Session cookies
We do not use third party cookies.
“Technically necessary cookies” are cookies that are required for the proper use of the website.
“First-party cookies” are cookies that are set by the website you are visiting.
So-called session IDs are stored in “session cookies”, which are used to assign your requests to the current session. This enables your computer to be recognised when you return to a website. Session cookies are automatically deleted when you close the browser.
We use cookies on the following legal basis: – Session Cookies – Legitimate Interests (Art. 6 Para. 1 p. 1 lit. f GDPR).
Local storage and session storage
Local storage" and “session storage” are technologies that store data locally in your browser, similar to cookies. Data entries here can be up to 5MB in size.
In contrast to cookies, the contents are not automatically transferred to the server and are therefore more suitable for storing data locally that is only needed locally, e.g. user settings.
Reading out information is only possible on the domain where this data was also written. It is also not possible to read out the data from a subdomain of the writing domain (e.g. subdomain.example.org
is a subdomain of example.org
).
Data in session storage is automatically deleted when you close the browser.
Data in local storage remains on your hard disk when you close the browser. You can remove the data via your browser settings.
We use neither session nor local storage.
More features and offerings on our platform
In addition to the purely informational use of our platform, we offer various services that you can use if you are interested. To do this, you will generally need to provide other personal information that we use to provide the service and to which the aforementioned data processing principles apply.
In part, we use external service providers to process your data. These have been carefully selected and commissioned by us, are bound by our instructions, and are regularly inspected.
Insofar as our service providers or partners are based in a country outside the European Economic Area (EEA), we will inform you of the consequences of this in the description of the offer.
Minors
Our offer is basically aimed at people who have reached the age of 16. Persons under the age of 16 should not submit any personal information to us without the consent of their parent or legal guardian.
Use of Matomo
We use Matomo on this platform to analyze the surfing behavior of visitors to this website. Matomo is a free, open-source software that is operated exclusively on our own servers. When you visit our website, the following data in particular is stored:
- your IP address
- key user data (e.g. country of origin, device type, operating system, browser used, screen resolution, main Language of the browser being used)
- number of page views
- unique visits (returning visitors over a certain period of time)
- time spent on the website
- bounce rate (visitors to a website who only generate a single page view)
- date and time of the requests
- access times
- most frequently visited pages
- entry and exit pages (e.g. title, url)
- outgoing referrals
- referrer (direct access, search engines, website)
- search terms used
- files that were clicked and downloaded
We do not use cookies for the evaluation, but analyze your visitor behavior using log files and a calculated visitor ID (i.e. the device fingerprint), which is determined by the above-mentioned information. Matomo compares your technical fingerprint with the fingerprints previously saved by all visitors. However, the comparison is only made for the fingerprint from the last 30 minutes. In addition, the calculation of the fingerprint changes every 24 hours.
This data is not transmitted to third parties.
After the collection of your IP address, it is anonymised. In this way, the IP address can no longer be assigned to you. The other personal data is further processed in aggregated form by compiling it into reports.
The legal basis for the use of Matomo is Art. 6 para. 1 lit. f GDPR – processing based on our legitimate interest in making our website more user-friendly and improving it by monitoring the number of visitors to our website. In particular, your interests are sufficiently taken into account by anonymising your IP address and not using cookies.
We delete your data as soon as we no longer need it to design and improve our website. This is usually the case immediately after your IP address has been anonymised. The other data is compiled after 14 days at the latest and thus loses its personal reference or is deleted after 30 days.
The provision of personal data is neither legally nor contractually required. However, the provision of this data is necessary in order to visit our website.
If you do not agree to the storage and analysis of this data from your visit, you can object to the storage and use of this data at any time by clicking below or by activating the “Do Not Track” request in your browser. Our system automatically recognises this when you use the “Do Not Track” default setting. You do not have to actively object.
If you actively object, a so-called opt-out cookie (a technically necessary cookie) will be stored in your browser, which means that Matomo will not collect any session data. Please note that the complete deletion of your cookies means that the opt-out cookie will also be deleted and may have to be reactivated by you. You will not suffer any legal disadvantages from the non-provision.
Order processors
We use external service providers (order processors). A separate order data processing agreement has been concluded with the service provider to ensure the protection of your personal data.
Our processors
The hosting of the domains https://platform.joinus4health.eu and https://joinus4health.eu, with all associated components (e.g. platform, e-mail, website) is carried out for us by netcup GmbH, Daimlerstraße 25, D-76185 Karlsruhe.
The content translation function is performed for us by DeepL SE; Maarweg 165; D-50825 Cologne.
Rights of data subjects
According to the GDPR, you are entitled to various rights, which result in particular from Art. 15 to 21 GDPR:
Revocation of consent
If your personal data is processed on the basis of consent which you have given us, you have the right to revoke your consent at any time. The revocation of consent does not affect the legality of the processing performed on the basis of the consent until the time of revocation.
You can contact us at any time to exercise your right to revoke consent.
Right to confirmation
You have the right to request confirmation from the controller that we are processing personal data concerning you. You can request this confirmation at any time using the contact details above.
Right to information
In the event that personal data is processed, you can request information about this personal data and the following information at any time:
- the purposes of the processing
- the categories of personal data being processed
- the recipients or categories of recipients to whom the personal data has been or is being disclosed, in particular in the case of recipients in third countries or international organisations
- if possible, the planned duration for which the personal data is stored or, if this is not possible, the criteria for determining this duration
- the existence of a right to rectification or erasure of the personal data concerning you, or to a restriction of processing by the controller or a right to object to such processing
- the existence of a right to lodge a complaint with a supervisory authority
- if the personal data is not collected from the data subject, all available information on the source of the data
- the existence of automated decision-making, including profiling, in accordance with Article 22 (1) and (4) GDPR and, at least in these cases, meaningful information about the logic involved and the scope and intended impact of such processing on the data subject
If personal data is transferred to a third country or to an international organisation, you have the right to be informed of the appropriate safeguards under Article 46 of the GDPR in connection with the transfer. We provide a copy of the personal data that is the subject of the processing. For any additional copies you request of a person, we may charge a reasonable fee based on our administrative costs. If your request is submitted electronically, the information must be provided in a standard electronic format, unless otherwise stated. The right to receive a copy under paragraph 3 shall not affect the rights and freedoms of others.
Right to rectification
You have the right to demand the immediate correction of incorrect personal data concerning you. Taking into account the purposes of processing, you have the right to request the completion of incomplete personal data, including by means of a supplementary statement.
Right to erasure (“right to be forgotten”)
You have the right to demand that the controller erase personal data concerning you without undue delay, and we are obligated to erase personal data without undue delay where one of the following grounds applies:
- the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed
- the data subject withdraws the consent on which the processing is based according to point (a) of Article 6(1), or point (a) of Article 9(2), and there is no other legal ground for the processing
- the data subject objects to the processing pursuant to Article 21(1) GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) GDPR;
- the personal data have been unlawfully processed
- 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 was collected in relation to the offer of information society services referred to in Article 8(1) GDPR
If the controller has made the personal data public and is obliged pursuant to paragraph 1 to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, that personal data.
The right to erasure (“right to be forgotten”) does not apply to the extent that the processing is necessary:
- to exercise the right of freedom of expression and information
- for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller
- for reasons of public interest in the area of public health in accordance with points (h) and (i) of Article 9(2) as well as Article 9(3) GDPR
- for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) GDPR in so far as the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing; or
- for the establishment, exercise or defence of legal claims
Right to restriction of processing
You have the right to request that we restrict the processing of your personal data if any of the following conditions apply:
- 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 their use instead
- the controller no longer needs the personal data for the purposes of the processing, but the data is required by the data subject for the establishment, exercise or defence of legal claims, or
- the data subject has objected to processing pursuant to Article 21(1) GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject
In the event that processing has been restricted under the aforementioned conditions, this personal data shall – with the exception of storage – only be processed with the data subject’s consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.
In order to exercise the right to restrict processing, the data subject may contact us at any time using the contact details provided above.
Right to data portability
You have the right to receive the personal data concerning you which you have provided to us in a structured, commonly used and machine-readable format and have the right to transmit that data to another controller without hindrance from the controller to which the personal data have been provided, to the extent that:
- the processing is based on consent pursuant to point (a) of Article 6 (1) or point (a) of Article 9 (2) or on a contract pursuant to point (b) of Article 6 (1) GDPR and
- the processing is carried out by automated means
In exercising your right to data portability pursuant to paragraph 1, you have the right to have the personal data transmitted directly from one controller to another, to the extent that this is technically feasible. The exercise of the right to data portability does not affect your right to erasure (“right to be forgotten”). That right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
Right to object
You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data which concerns you which is based on point (e) or (f) of Article 6 (1) GDPR, including profiling based on those provisions. If objection is made, the controller will no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.
In the event that personal data is processed for direct marketing purposes, you have the right to object at any time to processing of personal data concerning you for such marketing. This also applies to profiling to the extent that it is related to such direct marketing. If you object to processing for direct marketing purposes, your personal data shall no longer be processed for such purposes.
Regarding the use of information society services, and notwithstanding Directive 2002/58/EC, you can exercise your right to object by automated means using technical specifications.
Where personal data are processed for scientific or historical research purposes or statistical purposes pursuant to Article 89 (1), you, on grounds relating to your particular situation, have the right to object to processing of personal data concerning you, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
The right of objection can be exercised at any time by contacting the respective controller.
Automated individual decision-making, including profiling
You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects for you or similarly significantly affects you. This does not apply if the decision:
- is necessary for entering into, or performance of, a contract between the data subject and a data controller
- 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
- is based on the data subject’s explicit consent
The controller 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 his or her point of view and to contest the decision.
This right can be exercised by the data subject at any time by contacting the respective controller.
Right to lodge a complaint with a supervisory authority
You also have the right, without prejudice to any other administrative or judicial remedy, to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you as data subject consider that the processing of personal data relating to you infringes this Regulation.
Right to effective judicial remedy
Without prejudice to any other available administrative or judicial remedy, including the right to lodge a complaint with a supervisory authority pursuant to Article 77 GDPR, you have the right to an effective judicial remedy if you consider that your rights under this Regulation have been infringed as a result of the processing of your personal data in breach of this Regulation.
Links
If you use external links that are offered within the framework of our Internet pages, this data protection declaration does not extend to these links. Insofar as we offer links, we assure that no violations of applicable law were recognisable on the linked Internet pages at the time the link was set. However, we have no influence on compliance with data protection and security regulations by other providers. Therefore, please also inform yourself on the Internet pages of the other providers about the data protection declarations provided there.
Changes of our data protection regulations
We reserve the right to change our security and data protection measures if this becomes necessary due to technical developments. In these cases, we will also adapt our data protection notices accordingly. Therefore, please refer to the current version of our privacy policy.
Definitions and Explanations
Terms
The law requires that personal data be processed lawfully, in good faith and in a manner that is transparent to the data subject (“lawfulness, fairness, transparency”). To ensure this, we would like to inform you of the legal definitions that are used in this Privacy Statement:
Personal data
“Personal data” means any information relating to an identified or identifiable natural person (hereinafter the “data subject”). A natural person is considered to be identifiable if he or she can be identified directly or indirectly, in particular by association with an identifier such as a name, an identification number, location data, an online identifier, or one or more special features which express the physical, physiological, genetic, mental, economic, cultural or social identity of the natural person.
Processing
“Processing” means any operation or set of operations which is performed on 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.
Restriction of processing
“Restriction of processing” means the marking of stored personal data with the aim of limiting its processing in the future.
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.
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 is not attributed to an identified or identifiable natural person
Filing system
“Filing system” means any structured set of personal data which is accessible according to specific criteria, whether centralised, decentralised or dispersed on a functional or geographical basis.
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 European Union or Member State law, the controller or the specific criteria for its nomination may be provided for by European Union or Member State law.
Processor
“Processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
Recipient
“Recipient” means a natural or legal person, public authority, agency or another body, to which the personal data is disclosed, whether a third party or not. However, public authorities which may receive potentially personal data in the framework of a particular inquiry in accordance with European Union or Member State law shall not be regarded as recipients. The processing of that data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.
Third party
A “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.
Consent
The “consent” of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
supervisory authority
A “supervisory authority” is an independent public entity, established by a Member State in accordance with Article 51 GDPR.
Lawfulness of processing
The processing of personal data is only lawful if there is a legal basis for such processing. Pursuant to Article 6 (1) (a) – (f) of the GDPR, the legal basis for the processing may be in particular:
- a: The data subject has given consent to the processing of his or her personal data for one or more specific purposes
- b: Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract
- c: Processing is necessary for compliance with a legal obligation to which the controller is subject
- d: Processing is necessary in order to protect the vital interests of the data subject or of another natural person
- e: Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller
- f: Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.