Privacy Policy - Application

Thank you for your application to the University of Medicine, Pharmacy, Sciences and Technology of Targu Mureș (UMFST) at its Hamburg study location, the Targu Mureș Medical Campus Hamburg (UMFST-UMCH). You now have access to the dashboard and can use various services. The protection of personal data is very important to us. We process data exclusively in accordance with the applicable data protection regulations, in particular the General Data Protection Regulation (GDPR).

CPE Europe GmbH, acting as Campus Management, is responsible, among other things, for the provision of campus equipment and infrastructure. This Privacy Policy provides information about the nature, scope, and purpose of the processing of personal data in connection with the use of the dashboard.

I. Name and Address of the Responsible Person

The entity responsible for data processing in connection with our website is:

CPE Europe GmbH
Albert-Einstein-Ring 11-15
22761 Hamburg, Germany
represented by the managing directors (Geschäftsführung): Hon.-Prof. Christopher M. F. Musmann M.Sc. und Karina Krasnicka

Email: info@edu.umch.de
Phone: +49 (0) 40-2093485-00

II. Data Protection Officer

We have appointed an external data protection officer for our company. He can be reached at the following contact details:

CPE Europe GmbH
Der Datenschutzbeauftragte
Albert-Einstein-Ring 11-15
22761 Hamburg
Deutschland
Email: mail@planit.legal

III. General information on data processing

1. Scope of processing of personal data

As a general rule, we collect and use our users’ personal data only to the extent necessary to provide a fully functional website, as well as our content and services, and to the extent permitted by law.

2. Legal Basis for the Processing of Personal Data

To the extent that personal data is processed, the following legal bases apply in accordance with Article 6(1) of the GDPR: Consent of the data subject (lit. a), performance of a contract or pre-contractual measures (lit. b), compliance with a legal obligation (lit. c), and the protection of the legitimate interests of our company or a third party, provided that the interests, fundamental rights, and fundamental freedoms of the data subject do not take precedence (lit. f).

3. Data Deletion and Storage Periods

Personal data is deleted or blocked as soon as the purpose for which it was stored no longer applies or statutory retention periods expire, provided that further storage is not required for the conclusion or performance of a contract. Storage may also be required by law.

IV. Provision of the website and creation of log files

1. Description and scope of data processing, disclosure to third parties

Each time you access our website, our system automatically collects data and information from the computer system of the accessing computer. The following data is collected.

For the subdomain https://www.edu.umch.de the following data is collected:

The last two digits of the IP address are shortened, for example IP 11.22.33.44 becomes 11.22.0.0. Furthermore, no statistics about access logs are generated.

2. Purpose of Data Processing and Legal Basis

The temporary storage of the IP address is necessary to provide the website. Storing this information in log files serves to ensure the functionality, security, and optimization of the website. The data is not used for marketing purposes. The legal basis is Article 6(1)(f) of the GDPR (legitimate interest).

3. Storage Period

The data is deleted as soon as it is no longer necessary to achieve the purpose for which it was collected. The data is stored in our system’s log files for 90 days. Backups are retained for a maximum of 61 days.

5. Right to Object and Right to Removal

The collection of data for the purpose of providing the website and the storage of data in log files is absolutely necessary for the operation of the website. Consequently, the user has no right to object.

V. Use of Cookies

1. Description and scope of data processing

Our website uses cookies. Cookies are text files that are stored in the Internet browser or by the Internet browser on the user's computer system. When a user visits a website, a cookie can be stored on the user's operating system. This cookie contains a characteristic string of characters that enables the browser to be uniquely identified when the website is called up again. We use cookies to make our website more user-friendly. Among other things, we use cookies to store the user's preference for the language. There is also a cookie that is used when the user logs in but is deleted when the user disconnects. We do not use tracking cookies outside of Google Analytics.

2. Legal basis for data processing

The legal basis for the processing of personal data using cookies is Art. 6, para. 1, lit. f of the GDPR.

3. Purpose of data processing

The purpose of using technically necessary cookies is to simplify the use of websites for users, in particular, to save the user's preference for a language.

4. Duration of the storage, objection and removal possibility

a. Cookies are stored on the user’s computer and transmitted to our site by the user. Therefore, as a user you have full control over the use of cookies. You can deactivate or restrict the transmission of cookies by changing the settings in your Internet browser. Cookies that have already been saved can be deleted at any time. If cookies are deactivated for our website, it is possible that all functions of the website can no longer be used to their full extent.

b. The user may revoke their consent to the processing of personal data at any time and object to the storage of their data via email. In this case, communication cannot continue. We store customer-related emails for the duration of the communication; otherwise, we delete emails and contact information after 12 months of inactivity.

VI. Contact by Telephone for the Purpose of Consultation

1. Description and Scope of Data Processing

When you contact us by telephone or seek consultation, we process the personal data provided during the conversation. This includes, in particular, your name (if provided), telephone number, the content of the conversation, as well as the time and duration of the call, and any other information you voluntarily provide.

2. Legal Basis for Data Processing

Processing is based on Article 6(1)(b) of the GDPR (pre-contractual or contractual purposes), Article 6(1)(f) of the GDPR (legitimate interest in efficient communication), or Article 6(1)(a) of the GDPR (your consent for promotional calls). Legal requirements for promotional calls are observed. The provision of data in the context of telephone consultations is voluntary. You may use alternative contact methods (e.g., email or mail) at any time.

3. Purpose of data processing

Personal data is processed for the following purposes:

4. Duration of the storage, objection and removal possibility

The data collected during the phone call will be used exclusively for the purposes specified and will not be disclosed to third parties without your express consent, unless required by law.

VII. Use of Social Media and Messaging Services (WhatsApp)

We maintain profiles on social networks and communication platforms to provide information and communicate with users. In doing so, personal data is processed both by us and by the respective platform operators. Processing may take place outside the EU and, where necessary, is based on appropriate safeguards such as adequacy decisions or standard contractual clauses.

1. Description and Scope of Data Processing

WhatsApp is a service provided by WhatsApp Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, a Meta Platforms company. For more information on data processing, please see the provider's privacy policy: https://www.whatsapp.com/legal/privacy-policy-eea

2. Legal basis for data processing

When you contact us via WhatsApp, we process, in particular, your phone number, username (if provided), the content of your communications, and metadata (e.g., timestamps). This processing is based on Article 6(1)(a) of the GDPR (consent), (b) of the GDPR (contractual communication), or (f) of the GDPR (legitimate interest in efficient communication). In the case of promotional or proactive contact, processing is based on your consent. The processing serves to communicate with prospective students, applicants, students, and other users, in particular to respond to inquiries and to carry out pre-contractual measures, e.g., as part of application procedures.

3. Purpose of data processing

The data collected will be used exclusively to process the inquiry and will not be disclosed to third parties without your express consent, unless required by law.

4. Duration of the storage, objection and removal possibility

You may object to processing under Article 6(1)(f) of the GDPR at any time. In this case, communication via WhatsApp will be discontinued unless there are compelling legitimate grounds for further processing. Consent granted under Article 6(1)(a) of the GDPR may be withdrawn at any time with future effect.

VIII. Registration and Payment

Description and Scope of Data Processing

On our website, we offer users the option to register for an online application by providing personal data. The data is entered into a form, transmitted to us, and stored. The following data is collected as part of the registration process:

At the time of registration, the following data is also stored:

As part of the registration process, the user’s consent to the processing of this data is obtained. Furthermore, users have the option to process payments through the financial services provider Flywire:

Flywire
Attn: Privacy Officer
141 Tremont Street, 10th Floor
Boston, MA 02111, USA

When using this payment option, Flywire's privacy policy applies and can be accessed via this link: https://www.flywire.com/legal/privacy-policy

IX. Application

1. Description and scope of data processing

After a successful registration, the user must submit further documents to us online for their online application, such as school reports and curricula vitae. After a confirmation of admission, further documents, such as health certificates, are to be submitted in paper form. After an examination, these application documents will be forwarded to the University of Medicine, Pharmacy, Natural Sciences and Technology Neumarkt am Mieresch and to the Romanian Ministry of Education. Both an online application and a submission of the application in paper form are mandatory.

To complete your application, the following documents should be sent:

DreamApply (https://apply.umch.de) is the online application system that we use. Here, users and applicants can independently upload their application documents. For this purpose you must fill in the following fields.

Profile

Contact

Education

Languages

Other

2. Legal basis for the data processing

If the user has given his/her consent, the legal basis for the processing of the data is Art. 6, para. 1, lit. a of the GDPR. By sending documents, the user declares their consent to the further use of the documents within the scope of the online application. If the registration serves the fulfillment of a contract to which the user is a party or the implementation of pre-contractual measures, the additional legal basis for the processing of the data is Art. 6, para. 1, lit. b of the GDPR. This also applies to payment transactions that serve the fulfillment of the contract. The transfer of personally identifiable data to the University of Medicine, Pharmacy, Sciences and Technology of Târgu Mureș and to the Ministry of Education in Bucharest is accomplished also to fulfill the contract and its legally based on Art. 6, para. 1, lit. b of the GDPR. The legal basis for the processing of data by the user after registration for the newsletter is Art. 6, para. 1, lit. a of the GDPR if the user has given his consent.

3. Purpose of the data processing

The personally identifiable data listed under point 1 is processed exclusively in the context of the application process. These are precontractual pieces of information to help us decide if you can be offered a place of study as a user.

4. Duration of storage

The data will be deleted as soon as they are no longer necessary to achieve the purpose for which they were collected. This is the case for the fulfilment of precontractual measures during the application process, if the data is no longer necessary for a potential conclusion of the contract. If a contract is not concluded, the applicant data will be deleted at the beginning of the respective academic year and thereby as soon as the place of study can no longer be accepted.

5. Possibility of objection and removal

As a user, you have the chance to object to a further processing of your personal data submitted for the purpose of the application anytime. However, in this case the application process immediately ends and a contract can no longer be concluded. This does not apply to personally identifiable data that are tax-relevant and therefore subject to the 10-year archiving obligations under the Tax Code or to the 6-year archiving obligations under the Commercial Code.

X. Web Analysis by Google Analytics

1. Description and scope of data processing

This website uses Google Analytics, a web analytics service provided by Google Inc. (https://www.google.de/intl/de/about) (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, hereinafter referred to as “Google”). In this context, pseudonymized user profiles are created and cookies are used. The information generated by the cookie about your use of this website such as
Browser type/version
Operating system used,
Referrer URL (the previously visited page),
Host name of the accessing computer (IP address),
Time of the server request
are transferred to a Google server in the USA and stored there.

This information is used to evaluate the use of the website, compile reports on website activity and provide other services relating to website activity and internet usage for market research purposes, and to tailor these internet pages to meet requirements. Although this information is transferable to third parties – whether required by law or insofar third parties process this data – under no circumstances will their IP address be merged with any other data from Google. The IP addresses are anonymized so that an assignment is not possible (IP masking).

2. Legal basis for data processing

The legal basis for the processing of personal data using cookies is Art. 6, para. 1, lit. f of the GDPR. With the tracking measures used we want to ensure that our website is designed to meet requirements and is continually optimized. On the other hand, we use the tracking measures to record the use of our website statistically and evaluate it for the purpose of optimizing our offer. These interests are to be regarded as justified within the meaning of the aforementioned provision.

3. Purpose of the data processing

The purpose of the use is the continuous optimization and needs-based design of the website.

4. Duration of the storage, objection and removal possibility

Personal data is stored for 38 months. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that doing so may limit the functionality of this website. You can also prevent Google from collecting the data generated by the cookie and related to your use of the website (including your IP address) and Google from processing this data by downloading and installing the browser add-on available under the following link: . (https://tools.google.com/dlpage/gaoptout?hl=en ). As an alternative to the browser add-on, in particular for browsers on mobile devices, you can also prevent the collection by Google Analytics by clicking on this link. An opt-out cookie is set to prevent the future collection of your data when you visit this website. The opt-out cookie applies only to this browser and only to our website and is placed on your device. If you delete the cookies in this browser, you will need to set the opt-out cookie again. Further information on data protection in connection with Google Analytics can be found in the Google Analytics help (https://support.google.com/analytics/answer/6004245?hl=en).

XI. Google Adwords Conversion Tracking

1. Description and scope of data processing

In order to statistically record the use of our website and to evaluate our website for the purpose of optimization, we also use Google Conversion Tracking. Google AdWords places a cookie on your computer if you have accessed our website via a Google advertisement. These cookies lose their validity after 30 days and are not used for personal identification. If the user searches certain pages on the AdWords customer’s website and the cookie has not yet run, Google and the customer will be able to tell that the user clicked on the ad and was directed to that page. Each AdWords customer receives a different cookie. This means that cookies cannot be tracked through AdWords customer websites. The information collected from the Conversion cookie is used to generate conversion statistics for AdWords customers who have opted for Conversion Tracking. AdWords customers learn the total number of users who clicked on their ad and were directed to a page tagged with a conversion tracking tag. However, you will not receive any information that personally identifies users.

2. Legal basis for data processing

The legal basis for the processing of the data is Art. 6, para. 1, lit. a of the GDPR if the user has given his consent. The legal basis for the processing of data transmitted in the course of sending an e-mail is Art. 6, para. 1, lit. f of the GDPR. If the purpose of the e-mail contact is to conclude a contract, the additional legal basis for the processing is Art. 6, para. 1, lit. b of the GDPR.

3. Purpose of data processing

The processing of the data serves for statistical purposes and for the purpose of optimizing our website.

4. Duration of storage

The data will be deleted as soon as they are no longer necessary to achieve the purpose for which they were collected. For the personal data from the input mask of the contact form and those sent by e-mail, this is the case when the respective conversation with the user has ended. The conversation is terminated when it can be inferred from the circumstances that the relevant facts have been conclusively clarified. The additional personal data collected during the sending process will be deleted after a period of seven days at the latest.

5. Possibility of objection and removal

If you do not wish to participate in the tracking procedure, you can refuse to set a required cookie, for example, by setting your browser to generally deactivate the automatic setting of cookies. You can also deactivate cookies for conversion tracking by setting your browser to block cookies from the domain “www.googleadservices.com”. Google’s Privacy Policy for Conversion Tracking can be found at https://services.google.com/sitestats/de.html.

XII. Google Maps

1. Scope of processing of personal data

We use the Google Maps map service on our website via an API. The provider is Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA, 94043, USA. The data can be processed in the USA.

2. Legal basis for the processing of personal data

The legal basis for the processing of users’ personal data is Art. 6, para. 1, lit. f of the GDPR.

3. Purpose of data processing

The use of Google Maps enables an appealing presentation of our online presence and should give users the opportunity to easily find the places indicated on our website.

4. Duration of storage

The data is deleted as soon as it is no longer needed for recording purposes.

5. Possibility of opposition and removal

You can find more information about the handling of user data in Google’s privacy policy: : https://www.google.de/intl/de/policies/privacy. The settings can also be individually changed there. Opt-Out: https://adssettings.google.com/authenticated.

XIII. Rights of the Data Subject

If you process your personal data, you are the data subject within the meaning of the GDPR and are entitled to the following rights vis-à-vis the person responsible:

1. Right to information

You can request confirmation from the person responsible as to whether personal data relating to you will be processed by us.
In the event of such processing, you may request the following information from the data controller:
(1) the purposes for which the personal data will be processed;
(2) the categories of personal data processed;
(3) the recipients or categories of recipients to whom the personal data relating to you has been or will be disclosed;
(4) the planned duration of the retention of the personal data relating to you or if it is not possible to provide specific information in this regard, or the criteria for determining the retention period;
(5) the existence of a right to rectify or delete personal data concerning you, a right to limit the processing by the controller or a right to object to such processing;
(6) the existence of a right of appeal to a supervisory authority;
(7) all available information on the origin of the data, if the personal data are not collected from the data subject;
(8) the existence of automated decision-making including profiling in accordance with Art. 22 (1) and (4) of the GDPR and – at least in these cases – meaningful information on the logic involved and the scope and intended effects of such processing on the data subject.

You have the right to request information as to whether your personal data will be transferred to a third country or to an international organization. In this context, you may request information about the appropriate guarantees pursuant to Art. 46 of the GDPR regarding data transfer.

2. Amendment rights

You have the right to have your personal data corrected and/or completed by the data controller if your personal processed data is inaccurate or incomplete. The data controller must carry out the correction immediately.

3. The right to limit the processing

Under the following conditions, you may request that the processing of your personal data be restricted:
(1) if you dispute the accuracy of your personal data for a period of time which allows the controller to verify the accuracy of the personal data;
(2) the processing is unlawful and you refuse to erase the personal data and instead request that the use of the personal data be restricted;
(3) the controller no longer needs the personal data for the purposes of the processing, but you need them for the assertion, exercise or defense of legal claims, or
(4) if you have objected to the processing pursuant to Art. 21, para. 1 of the GDPR and it has not yet been established whether the legitimate reasons of the data controller outweigh yours.

If the processing of personal data concerning you has been restricted, such data – apart from their storage – may only be processed with your consent or for the assertion, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of an important public interest of the EU or a Member State. If the processing restriction has been limited in accordance with the above conditions, the controller will inform you before the restriction is lifted.

4. Right of cancellation

(a) Duty to delete
You may request the data controller delete your personal data immediately and the data controller is obliged to delete said data immediately if one of the following reasons applies:
Personal data relating to you shall no longer be necessary for the purposes they were collected for or otherwise processed.
(2) You revoke your consent on which the processing pursuant to Art. 6, para. 1, lit. a or Art. 9, para. 2, lit. a of the GDPR was based, and there is no other legal basis for the processing.
(3) You object to the processing pursuant to Art. 21, para. 1 of the GDPR and there are no overriding legitimate reasons for the processing or you object to the processing pursuant to Art. 21, para. 2 of the GDPR.
(4) Your personal data have been processed unlawfully.
(5) The deletion of your personal data is necessary to fulfill a legal obligation under EU law or those of the Member States to which the controller is subject.
(6) The personal data relating to you have been collected in relation to information society services offered pursuant to Art. 8 (1) of the GDPR.
b) Information to third parties
If the person responsible has made your personal data public and is obliged to delete them in accordance with Art. 17 (1) of the GDPR, they shall take appropriate measures – including technical measures, taking into account the available technology and the implementation costs – to inform the persons responsible for data processing who process the personal data that you, as the person concerned, have requested them to delete all links to this personal data or copies or replications of this personal data.
c) Exceptions
The right to deletion does not exist if the processing is necessary, such as:
(1) in the exercise of freedom of expression and information;
(2) to fulfill a legal obligation which processing is subject to EU law or those of the Member States to which the controller is subject or to perform a task carried out in the public interest or in the exercise of official authority vested in the controller;
(3) for reasons of public interest in the field of public health pursuant to Art. 9, para. 2, lit. h and i as well as Art. 9, para. 3 of the GDPR;
(4) for public interest archives, scientific or historical research, or for statistical purposes in accordance with Art. 89, para. 1 of the GDPR, insofar as the law referred to under a) is likely to make it impossible or seriously impair the attainment of the objectives of such processing, or
(5) to assert, exercise or defend legal claims.

5. Right to information

If you have exercised your right to correct, cancel or limit the processing of your personal data from the controller, the latter is obliged to notify all recipients your personal data has been disclosed to of such correction, cancellation or limitation, unless this proves impossible or involves a disproportionate effort. You have the right to be informed of such recipients by the data controller.

6. Right to data transfer

You have the right to receive your personal data that was provided to the responsible person in a structured, common and machine-readable format. In addition, you have the right to communicate these data to another data controller without being hindered by the controller to whom the personal data was provided, provided that
(1) the processing is based on consent pursuant to Art. 6, para. 1, lit. a of the GDPR or Art. 9, para. 2, lit. a of the GDPR or on a contract pursuant to Art. 6, para. 1, lit. b of the GDPR and
(2) the processing is carried out by automated means.

7. Right of objection

You have the right, for reasons arising from your particular situation, to object anytime to the processing of your personal data on the basis of Art. 6, para. 1, lit. e or f of the GDPR; this also applies to profiling based on these provisions. The person responsible will no longer process your personal data unless they can prove compelling grounds for processing worthy of protection that outweigh your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims. If your personal data are processed for the purpose of direct marketing, you have the right to object anytime to the processing of this personal data for said advertising purpose; this also applies to profiling insofar as it is connected with such direct marketing. If you object to processing for direct marketing purposes, the personal data concerning you will no longer be processed for such purposes. You have the possibility to exercise your right of objection through automated procedures using technical specifications in connection with the use of Information Society services, notwithstanding Directive 2002/58/EC.

8. Right to revoke the declaration of consent under data protection law

You have the right to revoke your declaration of consent under data protection law anytime. The revocation of your consent does not affect the legality of the processing carried out on the basis of your consent until you revoke it.

Without prejudice to any other administrative or judicial remedy, you shall have the right to complain to a supervisory authority, in particular in the Member State of your residence, place of work or place of presumed infringement, if you consider that the processing of your personal data is in breach of the GDPR. The supervisory authority with which the complaint was lodged shall inform the complainant of the status and outcome of the complaint, including the possibility of a judicial remedy under Art. 78 of the GDPR. The supervisory authority can be reached at the following contact details:

The Hamburg Commissioner for Data Protection and Freedom of Information
Ludwig-Erhard-Str 22, 7. OG
20459 Hamburg
Phone: +49 (0) 40 42854-4040
E-mail: mailbox@datenschutz.hamburg.de

An overview of the national and international data protection authorities is available here.