This data policy applies to the SuSanA platform susana.org, as well as to the following sub-domains: The SFD platform: sfd.susana.org, the SuSanA Discussion Forum: forum.susana.org, the FSM4 conference page: fsm4.susana.org, as well as the FSM5 conference page: fsm5.susana.org.
Data protection is of a particularly high priority for SuSanA. The use of the Internet pages of SuSanA is possible without any indication of personal data; however, if a person wants to use special services via our website, processing of personal data could 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.
The processing of personal data, such as the name, e-mail address, organization 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 SuSanA. 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.
SuSanA has implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through this website. However, Internet-based data transmissions may in principle have security gaps, so absolute protection may not be guaranteed.
The data protection declaration of SuSanA is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our data protection declaration should be legible and understandable for everyone. To ensure this, we would like to first explain the terminology used.
In this data protection declaration, we use, inter alia, the following terms:
Personal data means 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 is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.
Processing is 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
Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.
Pseudonymisation is 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
Controller or controller responsible for the processing is 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 is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
Recipient is 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 is 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 is 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.
2. Name and Address of the controller
Controller for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in Member states of the European Union and other provisions related to data protection is:
The secretariat of the Sustainable Sanitation Alliance, located at:
c/o Deutsche Gesellschaft für Internationale Zusammenarbeit (GIZ) GmbH
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.
4. Collection of general data and information
The website of SuSanA 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 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, SuSanA does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our website correctly, (2) optimize the content of our website, (3) ensure the long-term viability of our information technology systems and website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, SuSanA analyzes anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our enterprise, and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.
5. Registration on our website
The data subject has the possibility to register on the website of the controller with the indication of personal data. Which personal data are transmitted to the controller is determined by the respective input mask used for the registration. The personal data entered by the data subject are collected and stored exclusively for internal use.
By registering on the website of the controller, the IP address—assigned by the Internet service provider (ISP) and used by the data subject—date, and time of the registration are also stored. The storage of this data takes place against the background that this is the only way to prevent the misuse of our services, and, if necessary, to make it possible to investigate committed offenses. Insofar, the storage of this data is necessary to secure the controller. This data is not passed on to third parties unless there is a statutory obligation to pass on the data, or if the transfer serves the aim of criminal prosecution.
The registration of the data subject, with the voluntary indication of personal data, is intended to enable the controller to offer the data subject contents or services that may only be offered to registered users - like the active use of the forum. Registered persons are free to change the personal data specified during the registration at any time, or to have them completely deleted from the data stock of the controller.
The data controller shall, at any time, provide information upon request to each data subject as to what personal data are stored about the data subject. In addition, the data controller shall correct or erase personal data at the request or indication of the data subject, insofar as there are no statutory storage obligations. The entirety of the controller’s employees are available to the data subject in this respect as contact persons.
6. Subscription to our newsletters
On the website of SuSanA, users are given the opportunity to subscribe to our newsletter. The input mask used for this purpose determines what personal data are transmitted, as well as the frequency and type of the newsletters.
SuSanA offers a variety of newsletters for general news, updates on activities from the Working Groups, Discussion Forum digest, or the Regional Chapters. These newsletters may only be received by the data subject if (1) the data subject has a valid e-mail address and (2) the data subject registers for the newsletter shipping on the website.
During the registration for the newsletter, we also store the IP address of the computer system assigned by the Internet service provider (ISP) and used by the data subject at the time of the registration, as well as the date and time of the registration. The collection of this data is necessary in order to understand the (possible) misuse of the e-mail address of a data subject at a later date, and it therefore serves the aim of the legal protection of the controller.
The personal data collected as part of a registration for the newsletter will only be used to send our newsletter, Working Group updates, Discussion Forum digest or the Regional Chapter updates. In addition, subscribers to the newsletter may be informed by e-mail, as long as this is necessary for the operation of the newsletter service or a registration in question, as this could be the case in the event of modifications to the newsletter offer, or in the event of a change in technical circumstances. There will be no transfer of personal data collected by the newsletter service to third parties. The subscription to our newsletter may be terminated by the data subject at any time. The consent to the storage of personal data, which the data subject has given for shipping the newsletter, may be revoked at any time. For the purpose of revocation of consent, a corresponding link is found in each newsletter. It is also possible to unsubscribe from the newsletter at any time directly on the website of the controller, or to communicate this to the controller in a different way.
The newsletter of SuSanA contains so-called tracking pixels. A tracking pixel is a miniature graphic embedded in such e-mails, which are sent in HTML format to enable log file recording and analysis. This allows an anonymous statistical analysis of the success or failure of online marketing campaigns. Based on the embedded tracking pixel, SuSanA may see which links in the e-mail were called up by data subjects. The anonymous data of the newsletter tracking are stored separately from all personal data provided by a data subject.
Such personal data collected in the tracking pixels contained in the newsletters are stored and analyzed by the controller in order to optimize the shipping of the newsletter, as well as to adapt the content of future newsletters even better to the interests of the data subject. These personal data will not be passed on to third parties. After a revocation, these personal data will be deleted by the controller. SuSanA automatically regards a withdrawal from the receipt of the newsletter as a revocation.
8. Contact possibility via the website
9. Registration to Webinars
SuSanA website offers registration to online webinars. If a data subject registers to a webinar, 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, for example to send reminders before the webinar or recordings of the webinar to the participants. There is no transfer of this personal data to third parties and no longer term subscription to any mailing list by registering for a webinar.
10. Submission of abstracts to FSM conference series
SuSanA website offers submission of abstracts to the Feacal Sludge Management (FSM) conference series. If a data subject submits an abstract, 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 (reviewing submissions) or contacting the data subject, for example to send notifications about acceptance of the submission.
11. Comments function in SuSanA Discussion Forum
SuSanA offers users the possibility to leave individual posts on SuSanA Forum, which is on the websites of the controller. The forum is a web-based, publicly accessible portal, through which registered members may post questions or announcements or answer to forum threads.
If a data subject leaves a comment on the forum, the posts made by the data subject are also stored and published, as well as information on the date of the commentary and on the user's (pseudonym) chosen by the data subject. In addition, the IP address assigned by the Internet service provider (ISP) to the data subject is also logged. This storage of the IP address takes place for security reasons, and in case the data subject violates the rights of third parties, or posts illegal content through a given comment. The storage of these personal data is, therefore, in the own interest of the data controller, so that he can exculpate in the event of an infringement. This collected personal data will not be passed to third parties, unless such a transfer is required by law or serves the aim of the defense of the data controller.
The Discussion Forum moderators and SuSanA secretariat are not responsible for the quality and accuracy of information posted on the forum by SuSanA members. Users should always take information and advice they read on this forum as "use at your own risk".
12. 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.
13. 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, at any time, contact any employee of the controller.
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 grounds 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 SuSanA, he or she may, at any time, contact any employee of the controller. An employees of the SuSanA secretariat 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. An employee of the SuSanA secretariat 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.
SuSanA shall no longer process the personal data in the event of the objection, unless we 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 SuSanA 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 any employee of the SuSanA secretariat. 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 is 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, SuSanA 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 any employee of the SuSanA secretariat.
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.
14. Data protection provisions about the application and use of Etracker
On this website, the controller has integrated components of the enterprise Etracker. Etracker is a Web analytics service. Web analytics is the collection, gathering and analysis of data about the behavior of visitors to websites. A web analysis service captures, among other things, data about from which website a person has arrived on another website (the so-called referrer), which sub-sites of the website were visited or how often and for what duration a sub-site was viewed. Web analytics are mainly used for the optimization of a website and in order to carry out a cost-benefit analysis of Internet advertising. The data collected through the Etracker component is not used without first obtaining of a separate and explicit consent of the data subject to identify the data subject. This data is not merged with personal data or other data which contain the same pseudonym.
The operating company of Etracker is Etracker GmbH, Erste Brunnenstraße 1, 20459 Hamburg, Germany.
Etracker sets a cookie on the information technology system of the data subject. The definition of cookies is explained above. With each call-up to one of the individual pages of this Internet site, which is operated by the controller and into which an Etracker component was integrated, the Internet browser on the information technology system of the data subject is automatically prompted to transmit data for marketing and optimisation purposes to Etracker through the Etracker component. During the course of this technical procedure Etracker receives data that is used to create pseudonymous user profiles. The user profiles created in such a way are used for the analysis of the behaviour of the data subject, which has accessed Internet page of the controller and are evaluated with the aim of improving and optimizing the website. The data collected through the Etracker component is not used without first obtaining of a separate and explicit consent of the data subject to identify the data subject. This data is not merged with personal data or other data which contain the same pseudonym.
The data subject may, as stated above, at any time prevent the setting of cookies through our website by means of a corresponding adjustment of the Internet browser used and, permanently deny the setting of cookies. Such an adjustment to the Internet browser used would also prevent Etracker from setting a cookie on the information technology system of the data subject. In addition, cookies already set by Etracker may be deleted at any time via a Web browser or other software programs.
In addition, the data subject has the possibility of objecting to a collection of data relating to a use of this Internet site that are generated by the Etracker cookie as well as the processing of these data by Etracker and the chance to preclude such. For this purpose, the data subject must press the ‘cookie-set’ button under the link http://www.etracker.de/privacy?sid=58e31c864e66848984dfc79b8f6b51a9&id=privacy&et=V23Jbb&languageId=2 , which sets an opt-out cookie. The opt-out cookie used for this purpose is placed on the information technology system used by the data subject. If the cookies are deleted from the system of the data subject, then the data subject must call up the link again and set a new opt-out cookie.
With the setting of the opt-out cookie, however, the possibility exists that the websites of the controller are not fully usable anymore by the data subject.
The applicable data protection provisions of Etracker may be accessed under https://www.etracker.com/de/datenschutz.html.
15. Data protection provisions about the application and use of Piwik
You can prevent cookies from being installed by adjusting the settings on your browser software accordingly. You should be aware, however, that by doing so you may not be able to make full use of all the functions of our website.
16. The use of social media buttons with "Shariff"
On our website we promote a project by c't, called "Shariff". "Shariff" replaces the typical share-buttons of social networks and thereby protects surfing behavior
"Shariff" integrates the share buttons of social networks on our website as a graphic containing a link to the appropriate social network. By clicking on the appropriate icon you will be redirected to the services of your network. The Shariff button provides direct contact between the social network and our users only when the visitor actively clicks the 'Share' button. Only then will your data be transferred to the respective social network. If, however, the Shariff button is not clicked, no exchange will be made between you and the social network. For more information about the c't project "Shariff" visit http://www.heise.de/ct/artikel/Shariff-Social-Media-Buttons-mit-Datenschutz-2467514.html
We integrate the following social networks on our website with "Shariff":
17. Data protection provisions about the application and use of YouTube
On this website, the controller has integrated components of YouTube. YouTube is an Internet video portal that enables video publishers to set video clips and other users free of charge, which also provides free viewing, review and commenting on them. YouTube allows you to publish all kinds of videos, so you can access both full movies and TV broadcasts, as well as music videos, trailers, and videos made by users via the Internet portal.
The operating company of YouTube is YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, United States. The YouTube, LLC is a subsidiary of Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States.
With each call-up to one of the individual SuSanA Internet sites, and on which a YouTube component (YouTube video) was integrated, the Internet browser on the information technology system of the data subject is automatically prompted to download a display of the corresponding YouTube component. Further information about YouTube may be obtained under https://www.youtube.com/yt/about/en/. During the course of this technical procedure, YouTube and Google gain knowledge of what specific sub-page of our website was visited by the data subject.
If the data subject is logged in on YouTube, YouTube recognizes with each call-up to a sub-page that contains a YouTube video, which specific sub-page of our Internet site was visited by the data subject. This information is collected by YouTube and Google and assigned to the respective YouTube account of the data subject.
YouTube and Google will receive information through the YouTube component that the data subject has visited our website, if the data subject at the time of the call to our website is logged in on YouTube; this occurs regardless of whether the person clicks on a YouTube video or not. If such a transmission of this information to YouTube and Google is not desirable for the data subject, the delivery may be prevented if the data subject logs off from their own YouTube account before a call-up to our website is made.
YouTube's data protection provisions, available at https://www.google.com/intl/en/policies/privacy/, provide information about the collection, processing and use of personal data by YouTube and Google.
18. Use of maps from open street map
19. Use of Google Translate
The automatic translation service in the sidebar on this website is performed by Google Translate, a third party service which we have no control over. The service provides automated computer translations that are only an approximation of the websites’ original content.
The tool from Google Translate is only for your convenience. The generated translations should not be considered exact and and may sometimes include incorrect or even offensive language. We do not warrant the accuracy, reliability or timeliness of any information translated by this system and will not accept liability for loss incurred as a result. In addition, it might not be possible to translate some applications, files or items including graphs, photos or PDFs.
Google collects, stores and processes information to provide users with better services. This includes, for example, the language you speak, but includes your personal surfing and / or online behavior.
20. 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.
21. Period for which the personal data will be stored
22. Existence of automated decision-making
We do not use automatic decision-making or profiling.
Date of last revision is June 18th, 2018.