Central European University Private University – CEU GmbH (Quellenstraße 51, 1100 Vienna, Austria) and Közép-európai Egyetem – KEE (Nador u. 9.,1051 Budapest, Hungary) – understand that you are entrusting us with your personal data. We are fully committed to protecting that personal data. 

As a data controller, we have a responsibility to be transparent in our processing of your personal data and to tell you about the different ways in which we collect and use your personal data. We will process your personal data in accordance with the General Data Protection Regulation (2016/679 EU Regulation)* and the local applicable rules of the countries where we operate.

Alongside informing you of your rights in relation to your data, we are providing you with a tool on the exercise of those rights. 

Whenever we share your personal data with our service providers, we are accountable to you for the use and storage of that data.

This Privacy Notice relates to the collection, use, transfer, and retention of your personal data in Moodle. You can check the Data Protection Policy of CEU PU and other relevant information regarding data protection of CEU here: https://www.ceu.edu/privacy

*Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC.

1. Who are we and what we do

CEU’s e-learning, Moodle site (CEULearning) support the teaching and learning activities of CEU through providing a platform for online interactive activities and learning materials.

We do this in tandem with offices that serve as primary data stewards for these groups (including, for example, the Human Resources Office, for CEU employee data; and the Student Records Office, which manages student data, and various CEU departments and units).

In order to provide access to this platform CEU maintains and processes personal data collected during the course of our relationship with CEU students, faculty, staff, and external students, faculty and staff who take part or support a CEU course/program. The basic account information of CEU students, faculty and staff (user name, e-mail address, name of department) is transferred from MS Azure automatically, but the majority of the information we hold is obtained directly from you. We always aim to keep your details up to date by refreshing Moodle if we are notified of changes. We value our relationship with you and we use your personal data to ensure we contact you in the most appropriate way, improve our services, and ensure we work efficiently and effectively.

2. Contact details of the Data Controller

Közép-európai Egyetem

1051 Budapest
Nador u. 9. 
Phone: + 36 1 3273000

Central European University 

Quellenstraße 51

1100 Vienna

3. Contact details of the Data Protection Officer

The Legal Counsel and Data Protection Officer
Central European University 
Quellenstrasse 51 | A-1100 Vienna | Austria   
Email: privacy@ceu.edu

4. What is the purpose for processing your data?

Your personal data is used only for educational purposes and to comply with any applicable laws and regulations. Additionally, personal data may be used to operate the CEUlearning Site:
- to provide our Users with ongoing customer assistance and technical support;
- to be able to contact our Users with general or personalized service-related notices;
- to create aggregated statistical data and other aggregated and/or inferred non-personal information.

5. What is our legal basis for processing your data?

We take our responsibilities under data protection rules seriously and ensure the personal information we obtain is held, used and processed in accordance with the applicable data privacy rules. CEU processes the information outlined in this Privacy Notice in pursuit of our legitimate interest.

· Communicating with students, faculty, staff;
· Providing access to the CEUlearning platform and courses for external and internal students, faculty and staff for educational purposes;
· Furthering the University’s educational mission;
· Enabling the University to achieve its strategic goals;
· In order to ensure security, logs can be evaluated if necessary.

We may pursue these legitimate interests by contacting you in email. Information about how you can opt out from some or all contact from CEU, is outlined in the ‘Your rights’ section below.

Although CEU relies on legitimate interest as the legal basis for processing where this is not overridden by the interests and rights or freedoms of the data subjects concerned, it recognizes that it is not the only lawful ground for processing data. As such, where appropriate, CEU will sometimes process your data on an alternative legal basis – for example, based on a legal obligation (when reporting may be required to the Austrian authorities, for instance) or when you give your explicit consent to us to do so (all users accept the “code of conduct” when first logs in to the site).

6. What kind of personal data do we collect?

The personal data we collect, store and process, the majority of which is given to us by you, or imported from the MS Active directory, may include:

a) Details about your devices and use of this website (including your IP address, browser type and version, length of visit, page views and website navigation paths);

b) Your name, email address, department;

c) Any other personal information that you upload about yourself in courses or in your profile;

d) Logs of the learning and teaching process;

e) Information and data related to users, including grades, feedback comments, scores, completion data, access rights and group membership; 

f) Student activities in courses, like assignments, quizzes, etc.;

g) Within documents/resources uploaded to the course;

h) Forum posts, including special categories of personal data you voluntarily share while exchanging ideas and posting comments on a Moodle forum.

7. Who receives your information?

Personal data provided in the profile information is visible for other users of the site in a course context (email address, profile picture, and other information provided by the user);

Logs of the learning and teaching process, and student activities in courses, like assignments, and forum posts are available for the course instructors, departmental coordinators and the site administrators.  

Details about your devices and use of this website available only for the site admins.

Moodle may share your personal information with other integrated systems within the University if you utilize these services within the courses.

Panopto video platform - https://www.panopto.com/privacy/
Zoom - https://explore.zoom.us/en/gdpr/

The Turnitin service connected to the relevant activities is GDPR compliant and require consent from the users - https://help.turnitin.com/Privacy_and_Security/Privacy_and_Security.htm

Other external tools may be linked from courses by the instructors which use personal data - informing students regarding these is the responsibility of the instructors.

Moodle data is backed up at a facility managed by CEU IT, the backups are held for the purpose of reinstatement of the data, e.g. in the event of failure of a system component.
Moodle data is either stored within the data centers of CEU, or within third party cloud systems of the integrated services.

8. How long will your information be held?

Information and data uploaded to Moodle, including accounts, papers and contributions to courses, including contributions to chat rooms and discussion forums, ownership of resources and evidence of participation in other Moodle-based activities may be retained indefinitely.
Logs of the site are kept for 3 years for statistical purposes.

9. What are your rights?

You have a right

· to access your personal information,
· to object to certain types of processing,
· to rectify,
· to erase and
· to restrict processing your personal information where certain conditions apply
· to withdraw your consent at any time.

We welcome your questions or comments about our privacy or data protection practice, you can contact us at privacy@ceu.edu. For more information on your rights, if you wish to exercise any right, for any queries you may have or if you wish to make a complaint, please contact us via this form. In case of doubt about your identity, we may ask you to provide us with your identification information.

Should you wish to request help from the relevant national authority, their details are as follows:
Austrian Data Protection Authority https://www.data-protection-authority.gv.at/.

10. Security of your information

We are committed to holding your data securely and treating it with sensitivity. All data are held securely and in accordance with the relevant data privacy laws and our internal policies. We do not sell to or trade your data with any other organizations.

11. Future changes

If our information policies or practices change at some time in the future, we will post the changes on our website.

Last modified: Tuesday, 20 February 2024, 5:49 PM