RKC is a private educational institution for online masters level programmes in an exclusive partnership with the University of Cumbria (UK), the University of Salford (UK) and York St John University (UK) (hereinafter referred to as “Universities”).
On our websites college.ch, rkc.swiss, york.mba, salford.rkc.edu, rkc.edu we offer information about our products and services, online programme access (login required), newsletters and blogs.
Your data is protected in conformity with the Swiss Federal Act on Data Protection (SR 235.1; hereinafter referred to as “FADP”). For data processing according to the EU General Data Protection Regulation (EU 2016/679) please refer to the GDPR addendum below.
As we process most personal data electronically, we have taken appropriate IT organisational and technical measures (e.g., IT security) to ensure that your personal data is protected. We also regularly educate our employees in data protection and information security.
3 What Personal Data is Collected for What Purpose
We may collect your master data (e.g. first name, last name, gender, birthdate, country of birth, residence address, phone number, e-mail address, occupation, and photo); personal data about the services obtained; education data (e.g. course attendance and grades); payment transaction data; online preferences; your blogs/feedback, and alumni information.
Prospective students: Based on the consent you provided to us in the request catalogue page we will contact you with relevant information, upcoming activities, news, promotions, and events. You can unsubscribe from any message and opt out of any other communication by requesting to do so with an email to email@example.com.
Registered students: Your data will be used to fulfil our contractual obligations and will be passed to the relevant University.
We use your personal data to communicate with you and third parties (e.g. Universities); for evaluating, concluding and performing our educational online and onsite services to you; for billing purposes; or for market research, surveys and marketing, such as contacting you by postal mail or e-mail, and understand trends and needs of our prospective students, registered students and others using our website or other services we offer.;
Input fields on the website that are absolutely necessary for the provision of our educational services are marked accordingly during registration. The disclosure of personal data in non-marked input fields on the website is voluntary. You can inform us at any time that you no longer wish us to process your personal data you provided voluntarily.
Furthermore, we collect your surfing and usage data when you access our website. This data includes, for example, information about which browser and browser version you are using, when you accessed our website, which operating system you use, from which website (link) you accessed our website, which elements of the website you use, and how you use these elements. These personal data are stored together with the IP address of the device you are using to access our website. They serve to correctly display and optimise our website, to protect it against attacks or other infringements, and to personalise your user experience. We do not draw any conclusions about the data subject from these surfing and usage data. We only evaluate personal data anonymously, unless they are required to clarify infringements.
4 Newsletter and Blogging
If you subscribe to our newsletters you will receive them only from us, and can unsubscribe at any time by clicking the “unsubscribe” link from any message. From time to time we may use an external service to deliver the newsletter but only if it matches our high standards and the law regarding data security and privacy.
5 Retention Period
We only process your data until the purpose is fulfilled or as required by law.
If you have opened an account with us, we will store your data you provided for an unlimited period of time. However, you can request the deletion of your account at any time. We will delete your data, unless we are required otherwise by applicable law.
To refuse further business contact with a data subject due to misuse, payment default, or other legitimate reasons, we may store personal data for five years, or ten years in case of recurrence.
6 Processing by Third Parties and Abroad
Within the purpose agreed herein, we may have your data processed by our group entities, the Universities, or third parties (e.g. outsourcing partners, payment processor or consultants). You herewith also explicitly agree to our processing of your data abroad, i.e. in European or non-European countries, where the level of protection might not be as high as in Switzerland.
7 Inclusion of Third Party Elements on Our Web Site
Our website includes content from various third party providers, such as, for instance, videos from video platforms, such as Vimeo or YouTube, or social media button from platforms such as Facebook or Twitter. This content enables you to enjoy content from those platforms on our website or simply to share our content on the relevant social media networks.
When you browse our website, if such content is displayed as part of the website, a connection to the servers of the third party provider is automatically established. Personal data about your visit to our website, in particular your IP address, will be transmitted to this third party provider. Therefore, if you have signed in to that third party’s account at the time you visit our website (for example, with a Facebook or Google account), that third party may detect that you visited our website. You authorise us to share this information with the third party provider that hosts your social media account.
Cookies are data packets sent from the webserver of our website to your browser. They are stored on your computer and can be retrieved by the webserver at a later visit. Cookies store information about the online preferences of visitors to the website and enable us to improve the visitor experience.
Session cookies are used to uniquely assign to you or your Internet browser information stored on the webserver that are necessary when accessing the website (e.g., the online shop) during a web session (e.g., so that the contents of the shopping basket are not lost). Session cookies are deleted after closing your Internet browser.
Permanent cookies are used to save your preferences (e.g., preferred language) over several independent accesses to our website, i.e. even after closing your Internet browser or to enable automatic login. Permanent cookies are deleted according to the settings of your Internet browser (e.g., one month after your last visit). By using our website and the corresponding functions (e.g., language selection or auto login) you agree to the use of permanent cookies.
You can delete current session or existing cookies in your Internet browser at any time, and deactivate the setting of additional cookies in your browser settings. However, deactivation may affect the functionality you enjoy on our website.
9 Legal Bases of Processing
The legal justification, upon which we base our processing of personal data, is stipulated in article 13 FADP.
We reserve the right to store your first name and surname, postal address, and e-mail address of a data subject pursuant to article 13(1) FADP if, based on misuse, non-payment or similar legitimate reasons, we refuse to conclude any future contracts with you.
Furthermore, group entities may also process personal data pursuant to article 13(1) FADP.
10 Severability and Changes
If any provision of this Agreement is held to be invalid, illegal or unenforceable, the validity, legality and enforceability of the remaining provisions will in no way be affected or impaired as long as the intent of the Parties can be preserved.
Due to the further development of our website and offers or due to changed legal or official requirements, it may become necessary to change this data protection declaration. You will be informed about the changes.
11 Applicable Law and Place of Jurisdiction
Zurich, 1.3.2019 (Version 1)
This GDRP addendum (“Addendum”) stipulates in addition to the https://college.ch/privacy-policy how Robert Kennedy College Zürich GmbH, Technoparkstrasse 1, 8005 Zurich, Switzerland (hereinafter "RKC" or "we") processes personal data of its web users and customers located in the European Economic Area (“EEA”) based on the EU General Data Protection Regulation (“GDPR”; EU 2016/679).
The Addendum applies only if we process your personal within the scope of the GDPR, regardless of the means of processing.
You can contact us as follows:
Robert Kennedy College Zürich GmbH
RKC is represented by Prof. Dr. David Costa
Enquiries may be submitted to firstname.lastname@example.org.
In the European Union RKC is represented by:
GDPR-Rep.eu provided by
Maetzler Rechtsanwalts GmbH & Co KG
c/o Robert Kennedy College Zürich GmbH
Schellinggasse 3/10, 1010 Vienna, Austria
You can contact our data privacy officer here: https://gdpr-rep.eu/q/15753276
2 Processing by Third Parties and Abroad
We or the third parties may process personal data abroad, i.e. in European or non-European countries. We represent that the third parties will only use personal data according to the law and exclusively in the interest of RKC. These necessary contractual guarantees provided by the third parties are based on the standards of the European Commission (also recognised in Switzerland). You have the right to inspect the guarantees in these contracts (or parts thereof).
We share your personal data with third-party service providers that complete transactions or perform services on our behalf or for your benefit, such as:
- Payment and contribution processing;
- Customer relationship management (CRM) services;
- Marketing and analytics;
- Processing admissions applications;
- Alumni outreach and engagement;
- Event registration and coordination;
- Providing course platforms or tools that enable or enhance our offerings;
- Course registration and administration;
- Course evaluations and assessments;
- Enrolment verification;
- Research insights and analytics;
- Research collaboration;
- Educational operations and collaborations;
- Performing human resources administration; and
- System maintenance and security.
We may share your personal data with the Universities for the purposes of administering programs and services, such as:
- Cross-registration for courses and events with other universities;
- Course registration and administration;
- Course evaluations and assessments;
- Online education offerings through online platforms;
3 Research arrangements with the Universities. Legal Bases of Processing
The legal justification, upon which we base our processing of personal data under this Addendum, is stipulated in article 6(1)(a) GDPR (consent) and/or article 6(1)(b) GDPR (processing necessary for the performance of our agreement) and/or article 6(1)(c) GDPR (compliance with the law).
Our legal justification for processing your data is also based on legitimate interests pursuant to article 6(1)(f) GDPR, for instance for:
- Providing, improving and customizing our educational offerings;
- Administration of our operations;
- Promoting the success of our current and former students;
- Furthering research and understanding in fields of academic study;
- Maintaining an ongoing relationship with alumni, donors and prospective donors, and helping to connect them with others;
- Offering attendance to events and opportunities to volunteer;
- Conducting admissions research;
- Understanding how our online platforms are being used;
- Exploring ways to develop and grow our operations;
- Ensuring the safety and security of our students, faculty, fellows, employees and others;
- Enhancing protection against fraud, spam, harassment, intellectual property infringement, crime and security risks;
- Preventing plagiarism; and
- Meeting our obligations and enforcing our legal rights.
4 Retention Period
5 Processing Abroad
The European Commission has adopted standard data protection clauses, which provide safeguards for personal data transferred outside of the EEA. We may use standard contractual clauses when transferring your personal data from a country in the EEA to a country outside the EEA. If your personal data are affected, you can request a copy of our standard contractual clauses by contacting us as set forth in section 2 of this Addendum.
6 Your Rights
Upon request, we will inform you about and - if so - which personal data we process (right of confirmation, right of access).
At your request:
- we will cease processing personal data, in part or in full (right to withdraw your consent to the processing of personal data for one or more specific purposes; right to erasure (right “to be forgotten”)). Your request to be forgotten will also be communicated to third parties to whom we have previously forwarded your personal data.
- we will correct the relevant personal data (right to rectification);
- we will restrict the processing of the relevant personal data (right to restriction of processing); in this case we will only store or use your personal data to protect our own legal claims or the third party rights;
- you will receive the relevant personal data in a structured, commonly used and machine-readable format (right to data portability).
To request any of the rights described in this section, for example if you no longer wish to receive our e-mail newsletters or if you wish to delete your account, please use the appropriate function on our website, or contact our data protection officer or an employee as described in section 2 of this Addendum.
If we do not comply with your request, we will inform you of the reasons for our non-compliance. For example, we may legally refuse to delete your personal data if we still need it to fulfil the purpose, for which it was originally provided (for example if we continue providing our services to you), if the processing is based on mandatory law (for example mandatory accounting regulations), or if we have a predominant interest of our own (for example in the case of a lawsuit against the data subject).
If we assert a predominant interest in the processing of personal data, you have nevertheless the right to object to the processing; provided, however, that your individual situation compares differently to that of other data subjects (right to object). This could be the case, for example, if you are a person of public interest, or if processing increases the risk of you being harmed by third parties.
If you disagree with our response to your request, you have the right to file a complaint with a competent supervisory authority, for example, in your country of residence or at the registered seat of RKC (right to appeal).
Zurich, 1.3.2019 (Version 1)