This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users, identified at https://www.emba.unisg.ch and https://apply.emba.unisg.ch; 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 Master of Business Administration (EMBA-HSG).
2. How we use your personal data
- 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. You may opt-out of this at any point by visiting our preference center: email@example.com
We may process your account data (“account data“) that you provide to create an account on our website. The account data may include first name, last name, email, and password. The source of the account data is you. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent.
We may process your information included in your personal profile on our website or on your LinkedIn profile (“profile data“). The profile data may include your title, your name, address, country, telephone number, email address, profile pictures, gender, date of birth, Skype ID, LinkedIn profile link, educational details and employment details. The profile data may be processed for the purposes of enabling your use of our services. The legal basis for this processing is consent and our legitimate interests, namely the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
We may process information contained in any enquiry you submit to us regarding services, namely download brochures and registration for events (“enquiry data“). The enquiry data may include your first name, last name, email address, mobile phone number, country, work experience, academic education, EMBA programme you are interested in, city, gender, why you are considering an EMBA programme. 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 relating to transactions, including purchases of services (application for admission to our EMBA programme), that you enter into with us and/or through our website (“transaction data“). The transaction data may include title, first name, middle name, last name, preferred name, personal address, nationality, second nationality, date of birth, place of birth, gender, civil status, mobile number, landline number, work phone, Skype ID, secondary email address, results of GMAT, results of GRE, CPA qualification, CFA Level 2 qualification, English level, language skills, work experience, leadership experience, job title, company name, industry, business area, country of employment, nature of organization, responsibilities of job, international experience, activities and interests, three biggest achievements, career plans, highest degree, degree awarding institution(s), annual salary for your last three positions, intention of financing your EMBA, if you apply for a scholarship, if you are sponsored by a company, Swiss student ID Number, how you heard about us, other programmes to which you are applying, additional information, feedback, bachelor’s degree diploma, bachelor’s degree transcript(s), master’s degree diploma, master’s degree transcript(s), doctoral degree diploma, digital passport photograph, scanned passport page, curriculum vitae and other information. Further we will ask for reference contacts. The data about a reference contact may include title, first name, last name, email address, company, position, country of employment, telephone number, mobile number, rating of candidate, relationship to candidate, how long they have known the candidate, strengths of the candidate, most improvement of the candidate, description of communication skills of the candidate, potential of the candidate becoming a manager. For the payment of the application fee we will ask for your credit card details that are processed by our payment provider. The transaction data may be processed for the purpose of supplying the requested services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely the proper administration of our website and business.
We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletter (“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 insofar as necessary for the purposes, and on the legal bases, set out in this policy. Information about our institutes and schools can be found at https://www.unisg.ch/en/universitaet/institute and https://www.unisg.ch/en/universitaet/schools.
We may disclose your personal data to internal and external professional advisers insofar as reasonably necessary for the purposes of obtaining professional analysis and advice about enhancing the EMBA programme.
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, 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: firstname.lastname@example.org
Applications, brochure downloads and event registrations are handled by Full Fabric (UK) identified at https://fullfabric.com. We may disclose your enquiry and transaction data to Full Fabric for the purpose of processing your application, your brochure download request or your registration for an event insofar as reasonably necessary for processing your request.
For graduates of our EMBA programme, you automatically become an alumnus of the University of St.Gallen MBA. We may disclose (“account data”, “profile data”, “transaction data”) in the form of first name, last name, email address, phone number, graduation year to official alumni groups and representatives, including the EMBA alumni board. This information will be used to update you on the EMBA programme and alumni events. This information may also be disclosed to EMBA ranking providers, such as the Financial Times, Economist, Bloomberg, QS, Times Higher Education and others, for the purpose of participating in the rankings, as participation in various rankings requires a minimum level of responses from alumni.
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.
In Google Analytics, we will retain your personal data for 38 months, after which it will be deleted automatically.
In other cases, 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 Account 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:
Herr Thomas Jordan, lic. iur.
Stv. der Generalsekretärin / Juristischer Mitarbeiter Generalsekretariat
Universität St.Gallen (HSG)
Tel.: +41 71 224 24 21
Fax: +41 71 224 29 14
The University of St.Gallen
Executive Master of Business Administration (EMBA-HSG), 2018
2. About cookies
A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
3. Cookies that we use
Mandatory cookies are used to
increase the page speed of our website
protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally
Functional cookies are used to
- remember settings you have applied such as layout, language, or preferences
Performance cookies (Audience Measurement) are used to
- provide statistics on how our website is used
- see how effective our adverts are
- detect any errors that occur
- test different designs of our website
Targeting/Marketing/Personalization cookies are linked to services provided by third parties, such as ‘Like’ buttons and ‘Share’ buttons. We use them to
- link to social networks like Facebook, which may subsequently use information about your visit to target advertising to you on other websites
- provide advertising agencies with information on your visit so that they can present you with adverts that you may be interested in
Here is a list of some cookies installed on the website
|Name||Purpose||Type of Cookie||Link to More Information|
|Google Analytics||This is an Audience Measurement Tool. It provides statistics on how the website is used.||Performance||https://www.google.com/policies/privacy/|
|New Relic||This cookie is used for monitoring the performance of web and mobile applications.||Performance||https://newrelic.com/termsandconditions/privacy|
|RemX||This tool is used for the registration process||Functional||https://remx.ch/impressum/|
|Vimeo||Vimeo cookies enable the embedding of Vimeo videos on the website.||Functional||https://fullfabric.com/privacy-statement/|
|OpenStreetMap||This cookie is used to display maps on our website.||Functional||https://wiki.osmfoundation.org/wiki/Privacy_Policy|
|DoubleClick||The Google ad publishing and distribution network.||Targeting/Marketing/Perso nalization||https://support.google.com/dfp_premium/answer/2839090?hl=en|
|Social networking service that collects data through a range of plug-ins and integrations, that is primarily used for Facebook’s own tracking and targeting.||Targeting/Marketing/Perso nalization||https://www.facebook.com/policies/cookies|
|Social networking service that collects data via plug- ins and integrations, which is primarily used for LinkedIn’s tracking and targeting.||Targeting/Marketing/Perso nalization||https://www.linkedin.com/help/lms/answer/65521/the-linkedin-insight-tag-frequently-asked-questions|
|YouTube||YouTube collects user data in order to display targeted advertising to web visitors across a broad range of their own and other websites.||Targeting/Marketing/Perso nalization||https://www.youtube.com/static?template=privacy_guidelines|
4. Cookie preferences
Blocking all cookies will have a negative impact upon the usability of many websites. If you block cookies, you will not be able to use all the features on our website.
We reserve the right to make any changes and corrections to this Notice. Please refer to this page from time to time to review these and any new additional information.
The University of St. Gallen
Executive School of Management, Technology and Law (ES-HSG), 2018