1. General Information
This data policy applies to the entire Humanitarian Sanitation Hub (SaniHub) online platform which is currently hosted by German Toilet Organization e.V. (GTO). Data protection – particularly the protection of personal data such as name, email, organisation or country – is of high priority for GTO. Everyone has the right to know what happens to their own data.
The processing of personal data, such as the name, e-mail address, organisation or country of a data subject shall always be in line with the General Data Protection Regulation (GDPR), and in accordance with the country-specific data protection regulations applicable to GTO. By means of this data protection declaration, we would like to inform you of the nature, scope, and purpose of the personal data we collect, use and process. Furthermore, data subjects are informed, by means of this data protection declaration, of the rights to which they are entitled.
The use of the platform is possible without any indication of personal data; however, if a person wants to use special services via our platform, processing of personal data may become necessary. If the processing of personal data is necessary and there is no statutory basis for such processing, we generally obtain consent from the person.
GTO has implemented numerous technical and organisational measures to ensure the most complete protection of personal data processed through the SaniHub online platform. However, Internet-based data transmissions may in principle have security gaps, so absolute protection may not be guaranteed.
The data protection declaration of the SaniHub is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). This data protection declaration should be legible and understandable for everyone. To ensure this, you will find an explanation of the terminology used below.
In this data protection declaration, we use, inter alia, the following terms:
Personal data: Any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Data subject: Any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.
Processing: Any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Restriction of processing: The marking of stored personal data with the aim of limiting their processing in the future.
Pseudonymisation: The processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
Controller responsible for the processing: The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
Processor: A natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
Recipient: A natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.
Third Party: A natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data. Consent of the data subject: Any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
3. Name and Address of the Controller
The responsible body for the data processing on this website is:
German Toilet Organization e.V.P
GTO is a non-profit organisation registered according to German charity law and regulations (entry no. 25207 B in the register of societies at the district court Charlottenburg), represented by the executive board: Dr. Reinhard Marth, Dr. Kilian Langenbach, Barbara Wagner.
4. Collection of General Data and Information
The SaniHub website collects a series of general data and information when a data subject or automated system calls up the website. This general data and information are stored in the server log files. Collected data may be (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrers), (4) the sub-websites, (5) the date and time of access to the Internet site, (6) an Internet Protocol address (IP address), (7) the internet service provider of the accessing system, and (8) any other similar data and information that may be used in the event of attacks on our information technology systems.
When using these general data and information, GTO does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of the SaniHub website correctly, (2) optimise the content of our website, (3) ensure the long-term viability of the information technology systems and website technology used, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, GTO analyses anonymously collected data and information statistically, with the aim of increasing the data protection and data security, and to ensure an optimal level of protection for the personal data processed. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.
GTO is not able to identify you as person on the basis of the stored information. Art. 15 to 22 GDPR therefore do not apply in accordance to Art. 11 para. 2 GDPR, unless you provide additional information in order to exercise your rights under these articles, enabling identification.
5. Data Processing
GTO processes personal data in compliance with the relevant data protection regulations, in particular the GDPR and the BDSG. Data processing by GTO is only taking place on the basis of legal permission. When using this website, GTO will process personal data only with your consent (Art. 6 para. 1 letter a) GDPR), to fulfil a contract to which you are a party, or at your request to carry out pre-contractual measures (Art. 6 para. 1 letter b) GDPR), to fulfil a legal obligation (Art. 6 para. 1 letter c) GDPR), or if the processing is necessary to safeguard your rightful interests or the rightful interests of a third party, unless your interests or fundamental rights and freedoms, which require the protection of personal data, prevail (Art. 6 para. 1 sentence f) GDPR). GTO does not sell data to third parties. Consents to the collection or use of data may be revoked at any time coming into effect in the future.
6. Duration of Storing
Unless resulting otherwise from the following notices, GTO will only store the data for as long as necessary for achieving the purpose of processing or to fulfil contractual or legal obligations. Such legal storage obligations may arise in particular from commercial or tax law regulations. Requests to permanently delete and stop public display of personal data can be sent via e-mail to email@example.com. Such request may take up to 4 weeks to process.
7. Technical Service Providers
Unless resulting otherwise from the following notices, the data will be processed on the servers of technical service providers commissioned by GTO for this purpose. These service providers process the data only in accordance with explicit instructions and are contractually obliged to guarantee adequate technical and organisational measures for data protection.
8. Data Transmission to the USA
Visiting the SaniHub website may involve the transmission of certain personal data to the USA. For the transmission of data to the USA as a third country, i.e. a country in which the GDPR law does not apply, the European Commission has decided in accordance with Art. 45 GDPR that an adequate level of data protection is required for companies certified under the EU-US Privacy Shield. The transfer to the USA will then take place in a permissible manner.
9. Routine Erasure and Blocking of Personal Data
The data controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject to.
If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements.
The data subject may, at any time, prevent the setting of cookies through our website by means of a corresponding setting of the Internet browser used, and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. If the data subject deactivates the setting of cookies in the Internet browser used, not all functions of our website may be entirely usable.
11. Use of Google Analytics
The GTO website uses Google Analytics, a web analysis service provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (hereinafter referred to as “Google”). Google Analytics uses so-called cookies (small text files), which are stored on the user’s internet-enabled device and which make an analysis of the user’s website use possible. The information generated by a cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google evaluates the information collected to compile reports on website activity for website operators and to provide other services relating to website activity and internet usage. Google may transfer this information to third parties where legally required to do, or in case such third parties process data on Google’s behalf.
When visiting the SaniHub website, users may refuse the installation of cookies (opt-out function). Google Analytics sets a cookie to collect data about the use of the website only in the case of consent.
GTO uses Google Analytics only with activated IP anonymisation. This means that the IP address of the user is shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases is the full IP address transmitted to a Google server in the USA and shortened there. The IP address transmitted by the user’s browser is not merged with other Google data. Google offers a tool to deactivate the Google Analytics tracking.
12. Contact Possibilities via the Website
The SaniHub website contains information that enables a quick electronic contact to the SaniHub secretariat, its helpdesk and mailing list via the provided contact email (firstname.lastname@example.org) or via the provided contact form. If a data subject contacts the controller by e-mail or contact form, the personal data transmitted by the data subject are automatically stored. Such personal data transmitted on a voluntary basis by a data subject to the data controller are stored for the purpose of processing or contacting the data subject and to answer requests. There is no transfer of this personal data to third parties. The legal basis for the data processing is then Art. 6 para. 1 letter f) GDPR.
13. Embedded Services and Contents of Third Parties
GTO uses services, information and content (in the following collectively referred to as “Content”) provided by third parties on its website. For such an integration via inline frame, it is technically necessary to process your IP address so that the content can be sent to your browser. Your IP address will therefore be transmitted to the respective third party providers.
This data processing is carried out to safeguard GTO’s legitimate interests in the optimisation and economic operation of its website and is based on the legal basis of Art. 6 Para. 1 Letter f) GDPR. You can object to this data processing at any time via the settings of the browser used or certain browser extensions. One such extension is the matrix-based firewall matrix for the Firefox and Google Chrome browsers. Please note that this may restrict the functionality of the website.
14. External Links
The SaniHub website contains links to other websites. Where links are provided, GTO tries to ensure that they also comply with our data protection and security standards. However, GTO has no influence on the permanent or full compliance of other providers with data protection and security regulations and is in no way responsible for these other websites’ content. For this reason, please inform yourself about the data protection declarations on the websites of the other providers.
15. Rights of the Data Subject
Right of Confirmation
Each data subject shall have the right granted by the European legislator to obtain from the controller the confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact any employee of the controller.
Right of Access
Each data subject shall have the right granted by the European legislator to obtain from the controller free information about his or her personal data stored at any time and a copy of this information. Furthermore, the European directives and regulations grant the data subject access to the following information:
- The purposes of the processing;
- The categories of personal data concerned;
- The recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
- Where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
- The existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing;
- The existence of the right to lodge a complaint with a supervisory authority;
- Where the personal data are not collected from the data subject, any available information as to their source;
- The existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.
Furthermore, the data subject shall have a right to obtain information as to whether personal data are transferred to a third country or to an international organisation. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.
If a data subject wishes to avail himself of this right of access, he or she may, at any time, contact any employee of the controller.
Right to Rectification
Each data subject shall have the right granted by the European legislator to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement. If a data subject wishes to exercise this right to rectification, he or she may can contact the controller at any time.
Right to Erasure (Right to be Forgotten)
Each data subject shall have the right granted by the European legislator to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following reasons applies, as long as the processing is not necessary:
- The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
- The data subject withdraws consent to which the processing is based according to point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing.
- The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR.
- The personal data have been unlawfully processed.
- The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
- The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.
If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by GTO, he or she may, can contact the controller at any time. GTO shall promptly ensure that the erasure request is complied with immediately.
Where the controller has made personal data public and is obliged pursuant to Article 17(1) to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required. GTO will arrange the necessary measures in individual cases.
Right of Restriction of Processing
Each data subject shall have the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:
- The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
- The processing is unlawful and the data subject opposes the erasure of the personal data and requests instead the restriction of their use instead.
- The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims.
- The data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.
If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by SuSanA, he or she may at any time contact any employee of the controller. The employee of the SuSanA secretariat will arrange the restriction of the processing.
Right to Data Portability
Each data subject shall have the right granted by the European legislator, to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others. In order to assert the right to data portability, the data subject may at any time contact any employee of the SuSanA secretariat.
Right to Object
Each data subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR.
GTO shall no longer process the personal data in the event of the objection, unless GTO can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims.
In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her by GTO for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest. In order to exercise the right to object, the data subject may contact GTO at any time. In addition, the data subject is free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use his or her right to object by automated means using technical specifications.
Automated Individual Decision-Making, Including Profiling
Each data subject shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is not authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, or (3) is not based on the data subject’s explicit consent.
If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject’s explicit consent, GTO shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and contest the decision.
If the data subject wishes to exercise the rights concerning automated individual decision-making, he or she may, at any time, contact GTO at any time.
Right to Withdraw from Data Protection Consent
Each data subject shall have the right granted by the European legislator to withdraw his or her consent to processing of his or her personal data at any time. If the data subject wishes to exercise the right to withdraw the consent, he or she may, at any time, contact any employee of the SuSanA secretariat.
16. Processing in the Exercise of your Rights under Art. 12 to 22 GDPR
If you exercise your rights in accordance with Articles 12 to 22 of the GDPR, the GTO will process the provided personal information for the purpose of the implementation of these rights by GTO and in order to be able to provide proof thereof. The GTO will process stored data for the purpose of information provision and data protection control purposes only and will otherwise restrict the processing in accordance with Art 18 GDPR.
These processing operations are legally based on Art. 6 para. 1 letter. c) GDPR in connection with Art. 15 to 22 GDPR and § 34 para. 2 BDSG.
17. Legal Basis for the Processing
Art. 6(1) lit. a GDPR serves as the legal basis for processing operations for which we obtain consent for one or more specific processing purposes.
18. Data Protection Officer
GTO provides information on stored data free of charge in accordance with the statutory provisions. The data protection officer answers all inquiries regarding the collection, processing or use of personal data. In addition to the right to information, you have the right to have data corrected, blocked or deleted and to revoke any given consent given for the future in accordance with the statutory provisions.