General Legal Information and Data Protection
Usage of our online documents is subject to copyright. We accept no guarantee for the accuracy of information provided, or how up to date it is.
Please read the following information. By accessing the Internet platform of the University of St.Gallen and its institutes (hereinafter referred to as the University) you declare that you have understood and acknowledged the legal information stated below.
In so far as parts of this text do not, or no longer comply with current jurisdiction, the rest of the document remains unaffected in terms of its content and validity.
All online documents, websites and parts thereof are protected by copyright and may only be copied and printed out for private, research and non-commercial usage.
Without prior, written authorisation by the University of St.Gallen, the documents and websites, as well as parts thereof, may not be duplicated, nor saved on other servers, fed into newsgroups or online services, or saved on a CD ROM or other data media. Such specification shall apply in particular to the University’s logo.
Interim saving in a cache, or on a proxy server to enhance access speed is permitted.
Quoting documents and websites by stating the correct source, as well as placing links on our website is explicitly permitted. HSG, assessment level, context studies are registered trademarks of the University of St.Gallen in Switzerland and/or in other countries.
The University of St.Gallen accepts no liability whatsoever for the quality of the information provided, or such information being up to date, correct and complete. The University of St.Gallen reserves the express right to change the information at any time without any prior notice given.
Liability claims against the University of St.Gallen for damages of a tangible or intangible nature which arise from access, or usage, or non-usage of the information published, or abuse of the connection, or technical malfunctions, are excluded in so far as such exclusion is permitted by law.
The University of St.Gallen has not checked third-party websites that are merely linked to this Website via hyperlinks, i.e. which are not on its servers or within its sphere of influence, and accepts no responsibility for the content thereof, the products, services or other offers provided on such websites.
This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.
In this policy, “we”, “us” and “our” refer to the University of St. Gallen – Executive MBA HSG Team.
2. How we use your personal data
In this Section 2 we have set out:
- the general categories of personal data that we may process;
- in the case of personal data that we did not obtain directly from you, the source and specific categories of that data
- the purposes for which we may process personal data; and
- the legal bases of the processing.
We may process data about your use of our website and services (“usage data”). The usage data may include your geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system Google Analytics. This usage data may be processed for the purposes of analyzing the use of the website and services. The legal basis for this processing is your consent and our legitimate interests, namely monitoring and improving our website and services.
We may process information contained in any enquiry you submit to us regarding services, namely order programmes and registration for events (“enquiry data”). The enquiry data may include your salutation, first name, last name, email address, mobile phone number, programme interested, place of residence, city, post code, country, company, language. The enquiry data may be processed for the purpose of supplying the services mentioned above and keeping proper records of those transactions. The legal basis for this processing is consent.
We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data”). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.
We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
Please do not supply any other person’s personal data to us, unless we prompt you to do so.
3. Providing your personal data to others
We may disclose your personal data to any member of the University of St.Gallen and/or ETH Zurich insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
We may disclose your personal data to professional advisers insofar as reasonably necessary for the purposes of obtaining professional advice.
We may disclose (“usage Data”) to our advertising, analytics and social media providers insofar as is reasonably necessary to measure the success of and improve our advertising and social media efforts. This personal data may include IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. These advertising providers include Facebook, Google Adwords, Google DoubleClick, LinkedIn, AddToAny and Youtube. The legal basis for this processing and provision is consent. You may opt-out of this at any point by visiting our preference center.
We may disclose your enquiry data to “FULL FABRIC” identified at https://fullfabric.com/ for the purpose of processing your programme orders, information requests, or your registration for an event insofar as reasonably necessary for processing your request.
We may disclose your notification data to “Mailerlite” identified at https://www.mailchimp.com for the purpose of sending you relevant digital information insofar as reasonably we got your consent.
In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
4. International transfers of your personal data
In this Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside Switzerland and the European Economic Area (EEA).
Our Analytics Provider, Google Analytics, is situated in the United States of America. The European Commission has made an “adequacy decision” with respect to the General Data Protection Regulation. Transfers to the United States of America will be protected by appropriate safeguards, namely the EU-US Privacy Shield framework of which Google Analytics is a signatory. Information on the framework can be found here: https://www.privacyshield.gov/
Our Advertising and Social Media providers, listed in section 3, are located in the United States of America. The European Commission has made an “adequacy decision” with respect to the General Data Protection Regulation. Transfers to the United States of America will be protected by appropriate safeguards, namely the EU-US Privacy Shield framework of which all our advertising and social media providers are signatories. Information on the framework can be found here: https://www.privacyshield.gov/
5. Retaining and deleting personal data
This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
We will retain your personal data for a minimum of time.
It is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:
- the period of retention of Usage Data will be determined based on user requests for deletion or the data is no longer required.
- the period of retention for Enquiry Data will be determined based on user requests for deletion or the data is no longer required.
- the period of retention for Notification Data will be determined based on user requests for deletion.
- the period of retention for Correspondence Data will be determined based on user requests for deletion or the data is no longer required and the correspondence has been completed.
- Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
We may update this policy from time to time by publishing a new version on our website. You should check this page occasionally to ensure you are happy with any changes to this policy.
7. Your rights
In this Section 7, we have summarized the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
Your principal rights under data protection law are:
- the right to access;
- the right to rectification;
- the right to erasure;
- the right to restrict processing;
- the right to object to processing;
- the right to data portability;
- the right to complain to a supervisory authority; and
- the right to withdraw consent.
You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data.
You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for compliance with a legal obligation; or for the exercise or defense of legal claims.
In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defense of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the exercise or defense of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the exercise or defense of legal claims.
You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
To the extent that the legal basis for our processing of your personal data is:
- consent; or
- that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
- If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, Switzerland, your place of work or the place of the alleged infringement.
- To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
- You may exercise any of your rights in relation to your personal data by email or written notice to us. We may require a proof of identity.
8. Data protection officer
Our data protection officer’s contact details are: Thomas Jordan, firstname.lastname@example.org
The University of St. Gallen
Executive MBA HSG in General Management (EMBA HSG)