Website Privacy Policy
University of Twente (data controller) , with registered offices in Drienerlolaan 5, 7522 NB Enschede, Netherlands, VAT no. and Fiscal Code TEST, is committed to protecting the online privacy of the users of this website (“Website”).
As such, this Privacy Policy has been written in order to allow you to understand University of Twente’s policy regarding your privacy, as well as how your personal information will be handled when using the Website. This Privacy Policy will also provide you with information so that you are able to consent to the processing of your personal data in an explicit and informed manner, where appropriate.
In general, any information and data which you provide to University of Twente over the Website, or which is otherwise gathered via the Website by University of Twente, in the context of the use of Website’s services (“Services”) as better defined in Section 3 below, will be processed by University of Twente in a lawful, fair and transparent manner. To this end, and as further described below, University of Twente takes into consideration internationally recognised principles governing the processing of personal data, such as purpose limitation, storage limitation, data minimisation, data quality and confidentiality.
CONTENTS
1. Data controller
2. Personal Data processed
a. Name, contact details and other Personal Data
b. Special categories of Personal Data
c. Other persons’ Personal Data
d. Browsing data
e. Cookies
3. Purposes of processing
4. Grounds for processing and mandatory / discretionary nature of processing
5. Recipients of Personal Data – Data Processors
6. Other Recipients of Personal Data
7. Retention of Personal Data
8. Data subjects’ rights
9. Amendments
1. Data controller
University of Twente, as identified at the top of this Privacy Policy, is the data controller regarding all personal data processing carried out through the Website. You can contact University of Twente with any questions related to this Privacy Policy or the University of Twente’s personal data processing practices by sending a written communication to info@trust-itservices.com, or via the contact forms available on the Website.
2. Personal Data processed
When you use the Website, University of Twente will collect and process information regarding you (as an individual) which allows you to be identified either by itself, or together with other information which has been collected. University of Twente may also be able to collect and process information regarding other persons in this same manner, if you choose to provide it to University of Twente, also via the Website.
This information may be classified as “Personal Data” and can be collected by University of Twente both when you choose to provide it (e.g., when you subscribe to the newsletter or request other Services provided by University of Twente over the Website) or simply by analysing your behaviour on the Website.
Personal Data which can be processed by University of Twente through the Website are as follows:
a. Name, contact details and other Personal Data
In various areas of the Website – including, in particular, if you decide to create an account on the Website – you will be asked to submit information about yourself, such as your name, professional title, organisation name/type, primary (and secondary) domain of work/expertise, e-mail address, city/country of residence, address, gender, Twitter handle, LinkedIn profile, and picture. Mandatory fields will be marked as such in the online registration forms – it is not possible to process your registration if any of the mandatory fields are left incomplete.
In addition, whenever you communicate with University of Twente by submitting a general enquiry or a support ticket via the Website, as well as whenever you participate in surveys which may be available on the Website, University of Twente may collect additional information which you choose to provide.
Regarding any applications received, University of Twente may assess the professional social media accounts (e.g. LinkedIn, Twitter) or professional websites of candidates, where publicly available or disclosed by the candidate, as necessary to gain insight as to a candidate’s suitability for the position/function to which the candidate applied.
When signing up for an event via the Website (such as a workshop organised or promoted by the Website), you will also be asked to provide details such as your name, your Twitter handle, the dates on which you will be attending and other information of relevance for the management of your attendance. Your payment details (including debit/credit card number and bank account details as needed) will be processed via an external payment gateway.
b. Special categories of Personal Data
When signing up for an event via the Website (such as a workshop organised or promoted by the Website), you will also be asked whether you have any special dietary/access requirements which might need accommodation. These Personal Data may potentially qualify as “health data” or “data revealing your religious/philosophical beliefs”, which are special categories of personal data under Art. 9 GDPR, and will be processed only with your explicit consent.
Certain areas of the Website may include free text fields, where you can write messages to University of Twente or otherwise allow you to post various types of content on the Website, which may contain Personal Data. Where these fields are completely free, you may use them to disclose (inadvertently or not) more sensitive categories of Personal Data, such as data revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership. The content you upload in these fields may also (inadvertently or not) include other types of sensitive information relating to you, such as your genetic data, biometric data or data concerning your health, sex life or sexual orientation.
University of Twente asks that you do not disclose any sensitive Personal Data on the Website, unless you consider this to be strictly necessary. As it is totally optional to provide this information, if you nonetheless choose to do so, please mind that University of Twente requires your explicit consent to process this sort of Personal Data (which can be provided, e.g., by declaring that you “explicitly consent to the processing of my special categories of personal data for the purpose of assessing my candidacy”).
c. Other persons’ Personal Data
As mentioned in the previous section, certain areas of the Website include free text fields where you can write messages to University of Twente, or otherwise allow you to post various types of content on the Website. These messages and content may (inadvertently or not) include Personal Data related to other persons.
In any situation where you decide to share Personal Data related to other persons, you will be considered as an independent data controller regarding that Personal Data and must assume all inherent legal obligations and responsibilities. This means, among other things, that you must fully indemnify University of Twente against any complaints, claims or demands for compensation for damages which may arise from the processing of this Personal Data, brought by the third parties whose information you provide through the Website.
As University of Twente does not collect this information directly from these third parties (but rather collects them, indirectly, from you), you must make sure that you have these third parties’ consent before providing any information regarding them to University of Twente; if not, then you must make sure there is some other appropriate grounds on which you can rely to lawfully give University of Twente this information.
d. Browsing data
The Website’s operation, as is standard with any websites on the Internet, involves the use of computer systems and software procedures, which collect information about the Website’s users as part of their routine operation. While University of Twente does not collect this information in order to link it to specific users, it is still possible to identify those users either directly via that information, or by using other information collected – as such, this information must also be considered Personal Data.
This information includes several parameters related to your operating system and IT environment, including your IP address, location (country), the domain names of your device, the type of device, the URI (Uniform Resource Identifier) addresses of resources you request on the Website, the time of requests made, the method used to submit requests to the server, the dimensions of the file obtained in response to a request, the numerical code indicating the status of the response sent by the server (successful, error, etc.), and so on.
These data are used to compile statistical information on the use of the Website, to ensure its correct operation, as well as restore backup from possible failures of the Website and identify any faults and/or abuse of the Website. Save for this last purpose, these data are not kept for more than 60 business days.
e. Cookies
- Definitions, characteristics, and application of standards
Cookies are small text files that may be sent to and registered on your computer by the websites you visit, to then be re-sent to those same sites when you visit them again. It is thanks to these cookies that those websites can “remember” your actions and preferences (e.g., login data, language, font size, other display settings, etc.), so that you do not need to configure them again when you next visit the website, or when you change pages within a website.
Cookies are used for electronic authentication, monitoring of sessions and storage of information regarding your activities when accessing a website. They may also contain a unique ID code which allows tracking of your browsing activities within a website, for statistical or advertising purposes. Some operations within a website may not be able to be performed without the use of cookies which, in certain cases, are technically necessary for operation of the website.
When browsing a website, you may also receive cookies from websites or web servers other than the website being visited (i.e., “ third-party cookies”).
There are various types of cookies, depending on their characteristics and functions, which may be stored on your computer for different periods of time: “session cookies”, which are automatically deleted when you close your browser, and “persistent cookies”, which will remain on your device until their pre-set expiration period passes.
According to the law which may be applicable to you, your consent may not always be necessary for cookies to be used on a website. In particular, “ technical cookies” – i.e. cookies which are only used to send messages through an electronic communications network, or which are needed to provide services you request – typically do not require this consent. This includes browsing or session cookies (used to allow users to login) and function cookies (used to remember choices made by a user when accessing the website, such as language or products selected for purchase).
On the other hand, “profiling cookies” – i.e., cookies used to create profiles on users and to send advertising messages in line with the preferences revealed by users while browsing websites – typically require specific consent from users, although this may vary according to the applicable law.
- Types of cookies used by the Website
The Website uses the following types of cookies:
- Browsing or session cookies, which are strictly necessary for the Website’s operation, and/or to allow you to use the Website’s content and Services.
- Analytics cookies , which allow University of Twente to understand how users make use of the Website, and to track traffic to and from the Website.
- Function cookies , which are used to activate specific Website functions and to configure the Website according to your choices (e.g., language), in order to improve your experience.
University of Twente also uses third-party cookies – i.e.cookies from websites / web servers other than the Website, owned by thirdparties. These third parties will either act as independent datacontrollers from University of Twente regarding their own cookies (using the datathey collect for their own purposes and under terms defined by them) or as data processors for University of Twente (processing personal data onUniversity of Twente’s behalf).
- Profiling cookies , which are used to observe the preferences you reveal through your use of the Website and to send you advertising messages in line with those preferences.
For further information on how these third parties may use your information, please refer to their privacy policies:
- Facebook
- Google
- Instagram
- LinkedIn
- Twitter
- Youtube
The list of installed cookies is available in the Cookie Policy on the Website
- Cookie settings
You can block or delete cookies used on the Website via your browser options. Your cookie preferences will be reset if different browsers are used to access the Website. For more information on how to set the preferences for cookies via your browser, please refer to the following instructions:
You may also provide set your preferences on third-party cookies by using online platforms such as AdChoice.
CAUTION If you block or delete technical and/or function cookies used by the Website, the Website may become impossible to browse, certain services or functions of the Website may become unavailable or other malfunctions may occur. In this case, you may have to modify or manually enter some information or preferences every time you visit the Website.
3. Purposes of processing
University of Twente intends to use your Personal Data, collected through the Website, for the following purposes:
1. To allow you to create and maintain a registered user profile on the Website, to allow you to participate in different areas over the Website and exchange information/documents with other participants, to verify your identity and assist you, in case you lose or forget your login / password details for any of the Website’s registration services, to send you informative newsletters and other communications (linked to the collaborative areas which you participate in), to respond to your enquiries and requests for support, and to provide any other Services which you may request (“ Service Provision”);
2. To process your sign-up/registration forms for events and webinars hosted or supported by the Website, process your payment details for associated fees, track event attendance and publish attendee lists online (“Events/Webinars”);
3. To assess applications submitted via the Website, such as collaborating opportunities or for participating to events organised or sponsored by the Website, among others (“Applications”);
4. For marketing, promotional and publicity purposes, including to carry out direct marketing, market research and surveys, via e-mail, through push notifications / pop-up banners, through the Website’s official social media pages, […], regarding upcoming events organised by the Website, as well as events hosted by selected third parties (“Marketing”);
5. To include information on you as a registered Member within the Website database (“Database Publication”);
6. For future marketing, promotional and publicity purposes, by sending you direct e-mail marketing communication regarding events hosted and Services provided by the Website and which are of an identical or similar scope to those which you have previously signed up for or acquired via the Website (“Soft Opt-in”);
7. To create a profile of you as a Website user, through the use of profiling cookies and by collecting and analysing information on the preferences you select and choices you make in the Website, as well as your general activities on the Website. This profile will be used to give you information about other websites / services you may be interested in, and to show you information and advertisements which may be relevant to you and your interests. All algorithms involved in this processing are regularly tested, to ensure the processing’s fairness and control for bias (“ Profiling”);
8. For compliance with laws which impose upon University of Twente the collection and/or further processing of certain kinds of Personal Data (“ Compliance”);
9. For development and administration of the Website, in particular by use of data analytics regarding how you and other users make use of the Website, as well as the information and feedback you provide, to improve our offerings (“Analytics”);
10. To prevent and detect any misuse of the Website, or any fraudulent activities carried out through the Website, including by carrying out internal audits (“Misuse/Fraud”).
4. Grounds for processing and mandatory / discretionary nature of processing
University of Twente’s legal bases to process your Personal Data, according to the purposes identified in Section 3 , are as follows:
1. Service Provision : processing for these purposes is necessary to provide the Services and, therefore, is necessary for the performance of a contract with you – Art. 6(1)(b) GDPR. It is not mandatory for you to give University of Twente your Personal Data for these purposes; however, if you do not, University of Twente will not be able to provide any Services to you.
2. Events/Webinars: processing for these purposes is generally necessary to allow the University of Twente Team to respond to your request to sign up for an event/webinar and, therefore, is necessary for the performance of a contract with you – Art. 6(1)(b) GDPR. However, the tracking of event attendance and publication of attendee lists is done on the basis of the Website’s interests in managing events and allowing other participants to become aware of persons taking part at the event – Art. 6(1)(f) GDPR. It is not mandatory for you to give University of Twente your Personal Data for these purposes; however, if you do not, University of Twente will not be able to process your registration for an event/webinar.
3. Applications: processing for this purpose is needed in order for University of Twente to be able to consider your application and, therefore, is necessary to take steps at your request before (potentially) entering into a contract – Art. 6(1)(b) GDPR. It is not mandatory for you to give University of Twente your Personal Data for these purposes; however, if you do not, University of Twente will not be able to consider your applications.
4. Marketing: processing for these purposes is based on your consent – Art. 6(1)(a) GDPR. It is not mandatory for you to give consent to University of Twente for use of your Personal Data for these purposes, and you will suffer no consequence if you choose not to give it (aside from not being able to receive further marketing communications from University of Twente). Any consent given may also be withdrawn at a later stage (please see Section 8 for more information).
5. Database Publication: processing for this purpose is based on your consent – Art. 6(1)(a) GDPR. It is not mandatory for you to give consent to University of Twente for use of your Personal Data for these purposes, and you will suffer no consequence if you choose not to give it. Any consent given may also be withdrawn at a later stage (please see Section 8 for more information).
6. Soft Opt-In : processing for these purposes is based on University of Twente’s interest in sending you direct e-mail marketing communication regarding events and Services provided by University of Twente and which are identical or similar to those you have previously signed up for or acquired through the Website – Art. 6(1)(f) GDPR. You can block these communications, and you will suffer no consequence if you do so (aside from not being able to receive further communications from the Website), by objecting through the link provided at the bottom of all such communications.
7. Profiling: processing for this purpose is based on your consent, collected by means of the cookie pop-up banner and/or a specific tick box – Art. 6(1)(a) GDPR. It is not mandatory for you to give consent to University of Twente for use of your Personal Data for this purpose, and you will suffer no consequence if you choose not to (aside from not being able to benefit from greater personalisation of your user experience regarding the Website). Any consent given may also be withdrawn at a later stage (please see Section 8 for more information).
8. Compliance: processing for this purpose is necessary for University of Twente to comply with its legal obligations – Art. 6(1)(c) GDPR. When you provide any Personal Data to University of Twente, University of Twente must process it in accordance with the laws applicable to it, which may include retaining and reporting your Personal Data to official authorities for compliance with tax, customs or other legal obligations.
9. Analytics: Information collected for this purpose is used to allow University of Twente to understand how users interact with the Website and to improve the Website accordingly, with the aim to providing a better user experience – Art. 6(1)(f) GDPR.
10. Misuse/Fraud: Information collected for this purpose is used exclusively to prevent and detect fraudulent activities or misuse of the Website (for potentially criminal purposes) – Art. 6(1)(f) GDPR.
5. Recipients of Personal Data – Data Processors
Your Personal Data may be shared with the following list of entities (“ Data Processors”):
- The following entities are engaged in order to provide or support the Website and Services (e.g., hosting providers, e-mail platform providers, technical maintenance providers Website administrators and Website user administrators):
- Commpla Srl
Via Nino Bixio, 25
56125 Pisa - Italy
P IVA 01958380501
Data Processor email: info@trust-itservices.com - Trust-IT Srl
Via Nino Bixio,
25 56125 Pisa, Italy
Tel: +39 050 28359
Fax: +39 050 503325
P.I. e C.F. 01870130505
Data Controller email: inf@trust-itservices.com - CENTRE NATIONAL DE LA RECHERCHE SCIENTIFIQUE CNRS (CNRS)
rue MICHEL ANGE 3, PARIS 75794, France,
VAT number FR40180089013 - SCUOLA INTERNAZIONALE SUPERIORE DI STUDI AVANZATI DI TRIESTE (SISSA),
via BONOMEA 265, TRIESTE 34136, Italy
VAT number IT00551830326 - CINECA CONSORZIO INTERUNIVERSITARIO (CINECA),
via MAGNANELLI 6/3, CASALECCHIO DI RENO BO 40033, Italy,
VAT number IT00502591209 - FORSCHUNGSZENTRUM JULICH GMBH (FZJ),
WILHELM JOHNEN STRASSE, JULICH 52428, Germany,
VAT number DE122624631 - MAX-PLANCK-GESELLSCHAFT ZUR FORDERUNG DER WISSENSCHAFTEN EV (MPG),
HOFGARTENSTRASSE 8, MUENCHEN 80539, Germany,
VAT number DE129517720 - UNIVERSITE DE VERSAILLES SAINT-QUENTIN-EN-YVELINES. (UVSQ),
Avenue de Paris 55, VERSAILLES 78035, France
VAT number FR25197819444 - MEGWARE COMPUTER VERTRIEB UND SERVICE GMBH (MEGWARE)
NORDSTRASSE 19, Chemnitz 09247, Germany
VAT number DE140853167 - SLOVENSKA TECHNICKA UNIVERZITA V BRATISLAVE (STUBA)
VAZOVOVA 5, BRATISLAVA 81243, Slovakia
VAT number SK2020845255 - UNIVERSITAT WIEN (UNIVIE)
established in UNIVERSITATSRING 1, WIEN 1010, Austria
VAT number ATU37586901 - POLITECHNIKA LODZKA (TUL)
ULICA ZEROMSKIEGO 116, LODZ 90 924 Poland,
VAT number PL7270021895
6. Other Recipients of Personal Data
Your Personal Data may be shared with the following list of persons / entities (“Recipients”):
- Persons, companies or professional firms providing the University of Twente with advice and consultancy regarding accounting, administrative, legal, tax, financial and debt collection matters related to the provision of the Services and which act typically as data processors on behalf of the University of Twente;
- Persons authorised by University of Twente to process Personal Data needed to carry out activities strictly related to the provision of the Services, who have undertaken an obligation of confidentiality or are subject to an appropriate legal obligation of confidentiality (e.g., members of the team operating the Website, and other functions with access to Personal Data processed via the Website);
- Public entities, bodies or authorities to whom your Personal Data may be disclosed, in accordance with the applicable law or binding orders of those entities, bodies or authorities.
Additionally, with your consent, some of your Personal Data may be published in the webpages available online at the Website. Furthermore, when you sign-up for an event, you will be listed in attendee lists made available on the Website.
More information on these transfers is available upon written request to the Website Managing Team at the following address: info@trust-itservices.com.
7. Retention of Personal Data
Personal Data processed for Service Provision and Events/Webinars will be kept by University of Twente for the period deemed strictly necessary to fulfil such purposes – in any case, as these Personal Data are processed for the provision of the Services, University of Twente may continue to store this Personal Data for a longer period, as may be necessary to protect University of Twente’s interests related to potential liability related to the provision of the Services.
Personal Data processed for Applications will be kept by University of Twente for up to 5 years. University of Twente may contact applicants before the expiration of this period, in order to request an extension of the retention period.
Personal Data processed for Database Publication, Marketing and Profiling will be kept by University of Twente from the moment you give consent until it is withdrawn. Where it is not withdrawn, consent will be renewed at fixed intervals. Once consent is withdrawn (or not given, following a renewal), Personal Data will no longer be used for these purposes, although it may still be kept by University of Twente in particular as may be necessary to protect University of Twente’s interests related to potential liability related to this processing.
Personal Data processed for Soft Opt-In will be kept by University of Twente from the moment where it is provided by you to University of Twente (in the context of registrations for events or Services requested via the Website) until you object to this processing. Once you have objected, Personal Data will no longer be used for these purposes, although it may still be kept by University of Twente, in particular as may be necessary to protect University of Twente’s interests related to potential liability related to this processing.
Personal Data processed for Compliance will be kept by University of Twente for the period required by the specific legal obligation or by the applicable law.
Personal Data processed for preventing Misuse/Fraud will be kept by University of Twente for as long as deemed strictly necessary to fulfil the purposes for which it was collected.
More information on applicable retention periods is available upon written request to the Website Managing Team at the following address: info@trust-itservices.com.
8. Data subjects’ rights
As a data subject, you are entitled to exercise the following rights before University of Twente, at any time:
1. Access your Personal Data being processed by University of Twente (and/or a copy of that Personal Data), as well as information on the processing of your Personal Data;
2. Correct or update your Personal Data processed by University of Twente, where it may be inaccurate or incomplete;
3. Request erasure of your Personal Data being processed by University of Twente, where you feel that the processing is unnecessary or otherwise unlawful;
4. Request the restriction of the processing of your Personal Data, where you feel that the Personal Data processed is inaccurate, unnecessary or unlawfully processed, or where you have objected to the processing;
5. Exercise your right to portability: the right to obtain a copy of your Personal Data provided to University of Twente, in a structured, commonly used and machine-readable format, as well as the transmission of that Personal Data to another data controller;
6. Object to the processing of your Personal Data, based on relevant grounds related to your particular situation, which you believe must prevent University of Twente from processing your Personal Data; or
7. Withdraw your consent to processing (forMarketing, Database Publication, Soft Opt-in, and Profiling).
Please note that most of the Personal Data you provide to University of Twente can be changed at any time, including your e-mail preferences, by accessing, where applicable, your user profile created on the Website.
You can also withdraw consent for Marketing (for communications received via e-mail) or object to Soft Opt-In by selecting the appropriate link included at the bottom of every marketing e-mail message received. The same applies to the Website’s newsletter which you may have subscribed to and receive as a Service.
Consent for Profiling carried out by cookies may be withdrawn as described in Section 2(e). Where consent for Profiling was given via a specific tick box, you may withdraw this consent by changing your preferences, at any time, within your user profile created on the Website, where applicable.
Aside from the above means, you can always exercise your rights described above by sending a written request to the Website Managing Team at the following address: info@trust-itservices.com.
In any case, please note that, as a data subject, you are entitled to file a complaint with the competent supervisory authorities for the protection of Personal Data, if you believe that the processing of your Personal Data carried out through the Website is unlawful.
9. Amendments
This Privacy Policy entered into force on 1 October 2020
University of Twente reserves the right to partly or fully amend this Privacy Policy, or simply to update its content, e.g., as a result of changes in applicable law. The Website Managing Team will inform you of such changes as soon as they are introduced, and they will be binding as soon as they are published on the Website. The Website Managing Team therefore invites you to regularly visit this Privacy Policy in order to acquaint yourself with the latest, updated version of the Privacy Policy, so that you may remain constantly informed on how University of Twente collects and uses Personal Data.
