Personal Data Processing Policy | Alumni program of Univesity of Pardubice

Personal Data Processing Policy in the Alumni Register

Article I – Introduction

The Alumni Register is a service available at the Internet address (URL) http://absolventi.upce.cz ("Alumni Register").

Alumni Register is a service that allows its users under the conditions agreed in the Terms and Conditions, in particular, registering and verifying the User's eligibility to be enrolled in the Alumni Program, entering and updating contact information for communication with the University of Pardubice, entering and updating other data (e.g. occupational and employment data) as part of the feedback to the University of Pardubice and obtaining the Alumni Card and administration of other services.

The operator of the Alumni Register and the controller of personal data within the meaning of the relevant provisions of Regulation No. 2016/679 of the European Parliament and of the Council (EU) on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46 / EC "General Regulation or Regulation") is:

The University of Pardubice

public university established by law

With its registered office: Studentská 95, 532 10 Pardubice

Company Registration Number 00216275, VATIN CZ00216275

("University of Pardubice")

Through this document, the University of Pardubice fulfils its information obligation and provides the Alumni Register users with information on the method of personal data processing as well as information on the most common types of personal data processing that occur during the operation of the Alumni Register.

The University of Pardubice declares that all personal data in connection with the operation of the Alumni Register is processed in accordance with legislation, in particular in accordance with the General Regulation and Act No. 110/2019 Sb., on personal data processing.

Personal data processing in connection with the operation of the Alumni Register is further regulated by the following documents:

User Agreement (Alumni Register Terms of Use)
Cookies Policy
Introductory statement of the University of Pardubice on the protection of personal data

Article II –Personal Data Processing

Data subject

The data subject is the end user of the Alumni Register, a natural person whose alumni status has been verified; in exceptional cases it may be a natural person whose alumni status is still in the verification phase (the "User").

Categories of personal data processed

The University of Pardubice processes the following categories of personal data in connection with the operation of the Alumni Register:

Mandatory data provided by the User

Name, surname, year of birth, contact email

By definition, the Alumni Register allows its users to act only under their true identity, and therefore the provision of this personal data is necessary for the performance of the Agreement concluded between the Alumni Register user and the University of Pardubice.

Information on the study (faculty, year of completion, surname at the time of completion, program and field of study, including the type (e.g. undergraduate) and form (e.g. full-time)

By definition, the Alumni Register is intended only for those natural persons who have previously completed one of the study programs implemented by the University of Pardubice or its legal predecessors. Setting up an account is therefore preconditioned by the knowledge of data corresponding to the successful study of the User.

While the User may have completed more than one study program in the past, it is necessary to enter at least one of them to verify his/her alumni status. Information on other studies can be entered voluntarily by the User.

Work position

Information on work position (whether the User is employed, self-employed, etc.) does not precondition the establishment of an account in the Alumni Register in terms of verifying the alumni status, but it is an important statistical component of feedback for the evaluation of the University of Pardubice.

While this is a mandatory attribute, the User has the option to select the "I do not want to specify" option.

Data provided voluntarily by the User

The scope of voluntarily provided personal data further processed by the University of Pardubice is determined by the User himself/herself by directly entering, correcting or deleting his/her personal data in the settings of his/her profile within the Alumni Register. This is the personal information listed below.

Telephone number, mailing address

This data is used only for the possibility to contact the User by the University of Pardubice in connection with the Alumni Program.

Depending on the User's choice, the mailing address can be processed either once for sending the Alumni Card (and then deleted) or, with the User's prior consent, repeatedly, e.g. for sending materials related to the Alumni Program.

Country of residence, information on employment (name of employer, job position, country of employment, category of employment)

This is statistically significant information, which will also serve to better focus the communicated information and the benefits offered by the University of Pardubice.

Pre-nominal and post-nominal letters

They are used primarily for personalizing the form in which the University of Pardubice communicates with the graduate.

Technical attributes

Technical attributes include information that may not be entered directly by the User, but may be the result of his/her interaction with the Alumni Register or activity within the Alumni Program. This includes, in particular, information on identity verification (e.g. whether the User's identity has been verified, in what way, etc.) and information on the issued Alumni Card (e.g. card number, visual style, activation date, etc.)

Online identifiers

The online identifiers mainly include cookies, the processing of which is regulated in a special document Cookies Policy. However, it can also be authentication data (e.g. login name and password or information about the selected external authentication service, such as a Google account), which the User has chosen to use to authenticate himself/herself in the Alumni Register.

Personal data processing method

Personal data are usually processed automatically via the Alumni Register. Depending on the activation of other services provided by the University of Pardubice to participants in the Alumni Program and on the setting of the level of privacy in the user profile within the Alumni Register, personal data may also be processed by other information systems of the University of Pardubice.

The user profile within the Alumni Register is not public and the data contained therein are accessible only to the employees of the University of Pardubice, who are responsible for the implementation of the Alumni Program.

The User has the right to adjust the level of his/her privacy and the scope of personal data processed in the user profile. With the exception of the mandatory data, it is up to the User which personal data he/she decides to enter in his/her profile.

However, when using other services, part of the registered data may be transferred to the information systems of these services. Some of these data can be transmitted mandatorily (they are always defined within the contractual conditions of the relevant service), others optionally.

In the user profile in the Alumni Register, the User has the option to set the extent to which they may be made available to other services provided within the Alumni Program.

The University of Pardubice ensures that access to personal data processed in connection with the Alumni Program is limited to the necessary number of employees of the University of Pardubice. Personal data are processed mainly by the authorized employees of the University of Pardubice, who need access to personal data for the performance of their job duties and who are obliged to follow the internal standards of the University of Pardubice and to maintain confidentiality of all facts and data of which they have learned in the course of their work.

In the event that the University of Pardubice uses a processor to process personal data, this will always be on the basis of a contract concluded on the processing of personal data, which ensures the protection of the rights of data subjects and compliance with the General Regulation.

Legal basis of personal data processing

The University of Pardubice always processes personal data only on the basis of a permitted legal reason within the meaning of Article 6 of the General Regulation, to the extent necessary for the given purpose and for the time necessary to fulfil the given purpose. The University of Pardubice may process personal data for another purpose, only if this purpose is compatible with the purpose for which the personal data were collected.

execution and performance of the Agreement

The basic legal reason for processing the User's personal data in the sense of Article 6 of the General Regulation is the Agreement with the User, which the User concludes within the registration in the Alumni Register. The Alumni Register, as an entry point into the graduate program, is intended for a limited circle of users (non-public) and the User is not entitled to use the Alumni Register without consent to the contractual arrangements and these principles of personal data processing.

legitimate interest

Under the conditions defined in the General Regulation, the University of Pardubice is entitled to process personal data of users on the basis of a legitimate interest of the University of Pardubice. In order to do so, the University of Pardubice informs the User through this document about the right to object to the processing and the right to delete personal data, and is also obliged to assess the legitimacy of the processing in each specific case.

The processing of personal data on the basis of a legitimate interest most often occurs in the protection of services against misuse (including fraud prevention), debt and legal claims in general, direct marketing, network and information security measures or processing to report possible crimes or offenses.

fulfilment of a legal obligation

During the contractual relationship between the User and the University of Pardubice, the University of Pardubice may process the personal data of users also in case that the University of Pardubice is directly obliged to do so by generally applicable legislation.

consent to the processing of personal data

In the case of processing personal data on the basis of the User's consent (especially the processing of personal data provided voluntarily), the User has the right to revoke or reject his/her consent at any time.

Purpose of personal data processing

The University of Pardubice processes personal data in connection with the operation of the Alumni Register for the following purposes:

identification of the User before concluding the Agreement and verification of the right to include the User in the Alumni Program,
communication with the User, including questionnaire surveys and direct marketing by the University of Pardubice
personalization of the services provided so as to provide users with the highest possible added value,
ensuring the security of the Alumni Register and other services and protection against their misuse,
recovery of any receivables, including claims for damages,
statistical purposes - anonymized (aggregated) data are used by the University of Pardubice to generate statistics on graduates, their professions and fields of activity.

The University of Pardubice may process personal data for another purpose, only if this purpose is compatible with the purpose for which the personal data were collected.

Transfer of personal data (to the recipient)

The University of Pardubice is entitled to make personal data available/transfer to third parties only in cases where it is required or permitted by law, contract, legitimate interest or user consent.

The University of Pardubice does not transfer personal data to third countries outside the EU or to international organizations.

Time limit for personal data processing

If the account is cancelled by the User or the University of Pardubice, this data will no longer be used within the provision of the Alumni Program. However, it can still be stored internally for some time in the form of system backups, storage of operating logs, etc. The complete deletion of personal data from the cancelled account is usually performed by the University of Pardubice within 6 months of its cancellation.

The University of Pardubice retains some personal data of the User even after he/she cancelled his/her account, if it is necessary due to compliance with legal obligations, compliance with legal requirements, dispute resolution, maintaining security, prevention of fraud and abuse, enforcement of claims under the User Agreement, and for a period prescribed by law, otherwise for a maximum of 10 years.

If personal data is processed for the purposes of fulfilling the obligations imposed on the University of Pardubice by public law regulations, personal data will be processed for the period stipulated by law.

Simultaneously with the cancellation of the account in the Alumni Register, any accounts in other services used by the User will be cancelled. The period and conditions for deleting personal data in these other services may differ from the period and conditions in the Alumni Register. A specific description is always given in the conditions of a specific service.

Article III – Rights of data subjects (users)

Right to information on the processing of personal data

The University of Pardubice is obliged to provide the User with information on the processing of personal data in a concise, transparent and comprehensible manner, in particular data on the identification of the administrator, legal title and purpose of processing, information on the processing time.

The University of Pardubice fulfils this obligation through this document and Cookies Policy.

Right of access to personal data

Based on his/her request, the User has the right to obtain information on whether his/her personal data are processed by the University of Pardubice and, if so, to what extent. The User has the right to request a copy of the processed personal data. If the User so requests, the University of Pardubice is obliged to inform the User of the purpose of the processing, the recipient of the processed personal data, or other related information.

The User has access to his/her personal data through the setting of his/her user profile in the Alumni Register.

Right to rectification

The User has the right to request that the University of Pardubice change or rectify any of his/her personal data, if there has been any change (for example, change of surname, change of email, etc.).

The User has access to his/her personal data through the settings of his/her user profile in the Alumni Register, where he/she can change his/her user data.

The University of Pardubice is not obliged as a personal data controller to actively find out whether the personal data it collects about the User are current, incorrect or inaccurate, however, in case the User notifies this fact, the University of Pardubice is obliged to deal with this comment or request for correction. If the same conditions are met, the User also has the right to request the addition of personal data.

Right to erasure (be forgotten)

The right to erasure (be forgotten) means the obligation of the University of Pardubice to remove the User's personal data if at least one condition is met:

personal data are no longer needed for the purposes for which they were collected or otherwise processed,

the consent to the processing of personal data has been revoked (if the processing is based on consent) and there is no other legal basis for the processing,

the data subject objects to the processing and there are no overriding legitimate reasons for the processing,

personal data have been processed illegally,

personal data must be deleted as this is a legal obligation.

Right to object

This right of the User applies when personal data are processed on the basis of a legitimate interest. In justified cases, your personal data will be deleted after the recognition of your objection and the University of Pardubice will not process it further.

Right to the portability of personal data

The User has the right to request the University of Pardubice to transfer personal data to another controller and it is the University of Pardubice's obligation to provide and transfer this data in a structured, commonly used and machine-readable format.

Right to restrict processing

In the event that the conditions set out in the regulation are met (processing of outdated data or illegal processing), the User has the right to request that the University of Pardubice restrict the processing of personal data.

Article IV – Exercise of the rights of data subjects, Commissioner for Personal Data Protection, supervision

The University of Pardubice has appointed the Commissioner for Personal Data Protection, who oversees the proper performance of the activities of the University of Pardubice in the field of personal data protection. The Commissioner for Personal Data Protection is the place for exercising the rights of natural persons in the field of personal data as well as the contact point in case of requests, questions, suggestions or comments related to personal data protection.

Contact details of the Commissioner for Personal Data Protection:

PharmDr. Ing. Jiří Šafra, Ph.D.

Commissioner for Personal Data Protection

Department for Personal Data Protection

Phone: 466 036 565

Email: dpo@upce.cz

The Procedure for Processing Applications is listed on the public website of the University of Pardubice.

If the User's request or objection is not granted or upheld, the User has the right to go to court or by means of a complaint to the supervisory authority, which is:

Úřad pro ochranu osobních údajů (Office for Personal Data Protection)

Pplk. Sochora 27

170 00 Praha 7

Phone: 234 665 111

https://www.uoou.cz

Article V – Changes and Updates

UPDATES AND CHANGES TO THE POLICY. The University of Pardubice reserves the right to unilaterally amend this Agreement to a reasonable extent, especially in the event of a change in legislation, a technical change in the operation of the Alumni Register, due to the development or expansion of the Alumni Register, or in the event of a change in operational, organizational or business processes.

If the University of Pardubice makes any substantial changes to this Policy, it is obliged to notify the User of this fact via the e-mail address provided by the User in his/her profile or otherwise, so that the User has the opportunity to familiarize himself/herself with the changes before they take effect.

If the User does not agree with the proposed changes to this Policy, he/she is entitled to cancel his/her account.

If the User does not accept the new terms and conditions for the Alumni Register within the specified time after the University of Pardubice publishes changes to this Policy and sends the User a notification, the User shall be deemed not to agree with the changes as of the date of their entry into force and his/her account shall be cancelled.

Tyto Personal Data Processing Policy comes into force and effect on June 19, 2020.