PRIVACY POLICY
of VAMED Management und Service GmbH, Sterngasse 5, 1230 Vienna (hereinafter briefly „we“ or „controller“). Further information about us is available at https://edu.vamed.com/local/pages/privacy-policy. The Data Protection Officer of the controller is Mag. Per-Oliver Gustavson and can be reached at datenschutz@vamed.com and by post at VAMED Management und Service GmbH, Sterngasse 5, 1230 Vienna, attn Data Protection Officer.
We respect and protect your (hereinafter briefly “you” or “data subject”) rights to data protection and privacy and employ all measures required by law for protecting your personal data that is processed. From a data protection law point of view, we are the “controller” with regard to the processing activities relating to your personal data described herein when you use our E-Learning Platform “VAMED Education and Training” services. With regard to Cookies used on our website, please refer to the following information.
We use cookies to track the activity on our Service and we hold certain information.
Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags, and scripts to collect and track information and to improve and analyze our Service.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
Cookies we use are necessary for the following purposes:
Cookie Name | Data categories | Purpose | Expiration |
_ga | generated id, timezone, first access, last access, last login, current login, last ip address | Registers a unique ID that is used to generate statistical data on how the visitor uses the website. | 2 Years |
_gid | generated id, timezone, first access, last access, last login, current login, last ip address | Registers a unique ID that is used to generate statistical data on how the visitor uses the website. | Session |
You may contact us at any time with questions related to data protection and for exercising your rights as data subject. For doing so, please use our contact data provided above (https://edu.vamed.com).
In this privacy policy in terms of Articles 13 and sequ. of the General Data Protection Regulation (hereinafter briefly “GDPR)”, you may swiftly and easily gain an overview as to which of your personal data we process as well as for which purposes and on which legal basis we do so.
Furthermore, we inform you about (possible) recipients of your data and your statutory rights under the data protection law, which are also known as data subject rights.
1. Use of the E-Learning Platform “VAMED Education and Training”
1.1. For the purpose of processing personal data for the performance of the E-Learning Platform “VAMED Education and Training”, we process in addition to those general personal data (first name, last name, e-mail address) that are collected directly from the data subject the following personal data:
From E-Learning Platform “VAMED Education and Training” -users (hereinafter briefly „users“):
· General personal data (first name, last name, e-mail address)
· User image
· Role (student)
· Login credentials (username, password)
· Date and time of the last access to the course
· Date and time and type of accesses to activities and working materials in enrolled courses
· Course enrollment (date, role in course, enrollment type, faculty/institute assignment)
· Assessments received and/or awarded in enrolled courses
· Data on learning activities and learning work materials (file submissions, test attempts, assessments, date, feedback, accesses, attendances, group assignments, number of attempts, calendar dates, completion dates).
· Communication data (forum posts written and read, messages, list of contacts, chat messages, polls, comments).
· Information (name, date, time and comment) if a data request was made for the processing of personal data
which are stored in an individual-related way for this purpose for the duration of the business relationship and/or beyond that, up to the expiration of all legal storage periods (in particular according to tax law).
The input of this data is necessary for the mentioned purposes and the provision of the services.
1.2. This processing is performed based on the “performance of the contractual services” (Article 6 para. 1 lit. b) GDPR).
1.3. No automated individual decision-making, including profiling, occurs in terms of Article 22 paras. 1 and 4 GDPR.
1.4. In some circumstances, the following persons/entities (recipients in terms of the GDPR) have access to the following data of the data subject, respectively the following data is transmitted to these recipients, whereas our service-providers are contractually obliged to strictly comply with the data protection laws:
· Moodle / AWS Cloudservice, Eschborner Landstrasse 100, Frankfurt am Main, 60489, Germany receiving all data categories of the “VAMED Education and Training”-users for the purpose(s) of: platform operation.
· VAMED Service Kosovo LL.C, Kompleksi Banesor VERANDA C2.7, Lagjja Arbëria Objekti P+3+NK, 10000 Pristina, Kosovo (legal basis: Standard Contractual Clauses pursuant to Commission Implementing Decision 2021/814/EU of 4 June 2021 (Annex C) or any amendments to same by the European Commission) receiving all data categories of the VAMED Education and Training”
- users for the purpose(s)of: VAMED Education and Training”,
- users for the purposes(s) of: platform administration and software development.
2. Information about the Data Subjects‘ Rights under Data protection Law
2.1. Right to withdraw your consent: To the extent the processing of your data is based on your consent, you have the right to withdraw your consent at any time, whereas the legitimacy of the processing that occurred on the basis of your consent remains untouched until your withdrawal. At each of your consent declarations, processes for declaring your withdrawal are described. You may also declare your withdrawal of your specific consent declarations at any time by sending your corresponding withdrawal-declaration to our contact information mentioned at the top of this privacy policy.
2.2. Right to Information: Every data subject has the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data (copy of the personal data which are the subject of the processing) and the following information: (a) the purposes of the processing; (b) the categories of personal data concerned; (c) the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations; (d) where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period; (e) 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; (f) the right to lodge a complaint with a supervisory authority; (g) where the personal data are not collected from the data subject, any available information as to their source;(h) the existence of automated decision-making, including profiling. The controller shall provide a copy of the personal data undergoing processing. For all further copies which the data subject requests, the controller may request a reasonable fee on the basis of administrative costs. Where the data subject makes the request by electronic means, and unless otherwise requested by the data subject, the information shall be provided in a commonly used electronic form.
2.3. Right to Rectification and Erasure: The data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. 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. The data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies: (a) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; (b) the data subject withdraws consent on which the processing is based, and where there is no other legal ground for the processing; (c) the data subject objects to the processing (see below); (d) the personal data have been unlawfully processed; (e) the personal data have to be erased for compliance with a legal obligation in the EU or member state law to which the controller is subject; (f) the personal data have been collected in relation to the offer of information society services (consent of a child).The right to erasure does not apply to the extent that processing is necessary for compliance with a legal obligation of the controller, or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller, and/or for the establishment, exercise or defence of legal claims.
2.4. Right to Restriction of Processing: The data subject has the right to obtain from the controller restriction of processing where one of the following applies: (a) 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; (b) the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead; (c) the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims; or (d) the data subject has objected to processing pending the verification whether the legitimate grounds of the controller override those of the data subject. Where processing has been restricted, such 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. A data subject who has obtained restriction of processing shall be informed by the controller before the restriction of processing is lifted.
2.5. Right to Data Portability: Insofar as the processing is based on consent or a contract and the processing is carried out by automated means, the data subject has the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format. In exercising his or her right to data portability pursuant to paragraph 1, the data subject shall have the right to have the personal data transmitted directly from one controller to another, where technically feasible.
2.6. Right to Object: The data subject shall have the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which 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 or the purposes of the legitimate interests pursued by the controller or by a third party. The controller shall then no longer process the personal data, except where he prove compelling legitimate grounds for the processing, which override the interests or fundamental rights and freedoms of the data subject, or the processing serves the establishment, exercise or defence of legal claims. Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing. If the data subject objects to the processing for the purposes of direct marketing, the personal data shall no longer be processed for this purpose.
2.7. Right to File a Complaint with a Supervisory Authority: Every data subject has the right to file a complaint with a supervisory authority without prejudice to other administrative or judicial legal remedies, in particular in the member state of their residence, their workplace or the place the alleged offense occurred, if the data subject is of the view that the processing of personal data concerning him or her breaches these legal provisions. The contact information of the Austrian Data Protection Authority can be found here: https://www.dsb.gv.at/; currently, the contact information is: Barichgasse 40-42, A-1030 Vienna, telephone: +43 1 52 152-0, email: dsb@dsb.gv.at, web: https://www.dsb.gv.at.
Privacy policy as per June 2021