Privacy policy

Introduction

Data protection is of a particularly high priority for the management of the Icelandic High Performance Computing National Competence Center. The use of the Internet pages of the IHPC is possible without any indication of personal data; however, if a data subject wants to use special enterprise 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 data subject.

The processing of personal data, such as the name, address, e-mail address, or telephone number 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 the IHPC. By means of this data protection declaration, our enterprise would like to inform the general public 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.

As the controller, the Icelandic High Performance Computing National Competence Center 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. For this reason, every data subject is free to transfer personal data to us via alternative means, e.g. by telephone.

1. Definitions

‍The data protection declaration of the IHPC 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 the general public, as well as our customers and business partners. To ensure this, we would like to first explain the terminology used.

In this data protection declaration, we use, inter alia, the following terms:

a) Personal data

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.

b) Data subject

Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.

c) 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.​

d) Restriction of processing

Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.

e) Profiling

Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

f) Pseudonymisation

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.

g) Controller or 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.

h) Processor

Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

i) Recipient

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.​

j) Third party

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.​

k) Consent

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:

Icelandic High Performance Computing National Competence Center
Department of Computer Science
Bjargargata 1
102 Reykjavík
Iceland
Website: ihpc.is
E-Mail: info@ihpc.is

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3. Name and Address of the Data Protection Officer

The Data Protection Officer of the controller is:

Morris Riedel
Icelandic High Performance Computing National Competence Center
Department of Computer Science
Bjargargata 1
102 Reykjavík
Iceland
Website: ihpc.is
E-Mail: info@ihpc.is

Any data subject may, at any time, contact our Data Protection Officer directly with all questions and suggestions concerning data protection.

4. Collection of general data and information

‍The website of the Icelandic High Performance Computing National Competence Center 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, the Icelandic High Performance Computing National Competence Center does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our website correctly, (2) ensure the long-term viability of our information technology systems and website technology, and (3) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, the Icelandic High Performance Computing National Competence Center 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. Contact possibility via the website

The website of the Icelandic High Performance Computing National Competence Center contains information that enables a quick electronic contact to our enterprise, as well as direct communication with us, which also includes a general address of the so-called electronic mail (e-mail address). If a data subject contacts the controller by e-mail, 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. There is no transfer of this personal data to third parties.

6. 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.

7. Rights of the data subject

‍a) 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.

b) 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:
... [This section remains unchanged, as it pertains to general GDPR rights and provisions.]

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.

c) 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 Icelandic High Performance Computing National Competence Center.

d) 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 the Icelandic High Performance Computing National Competence Center, he or she may, at any time, contact any employee of the controller. An employee of IHPC 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 IHPC will arrange the necessary measures in individual cases.

e) 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 defense 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 the Icelandic High Performance Computing National Competence Center, he or she may at any time contact any employee of the controller. The employee of IHPC will arrange the restriction of the processing.

f) 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 Icelandic High Performance Computing National Competence Center.

g) 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. This also applies to profiling based on these provisions.

The Icelandic High Performance Computing National Competence Center 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 defense 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 the Icelandic High Performance Computing National Competence Center 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 Icelandic High Performance Computing National Competence Center. 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.

h) 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 authorized 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, the Icelandic High Performance Computing National Competence Center 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 Icelandic High Performance Computing National Competence Center.

i) Right to withdraw 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 the Icelandic High Performance Computing National Competence Center.
Contact: info@ihpc.is

8. 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 a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service, the processing is based on Article 6(1) lit. b GDPR. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services. If IHPC is subject to a legal obligation by which processing of personal data is required, such as for the fulfillment of tax obligations, the processing is based on Art. 6(1) lit. c GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if a visitor were injured in our facility and his name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other third party. Then the processing would be based on Art. 6(1) lit. d GDPR. Finally, processing operations could be based on Article 6(1) lit. f GDPR. This legal basis is used for processing operations which are not covered by any of the abovementioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by IHPC or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. Such processing operations are particularly permissible because they have been specifically mentioned by the European legislator. He considered that a legitimate interest could be assumed if the data subject is a client of the controller (Recital 47 Sentence 2 GDPR).

9. The legitimate interests pursued by the controller or by a third party

‍Where the processing of personal data is based on Article 6(1) lit. f GDPR, our legitimate interest is to carry out our academic and research activities in favor of the betterment of the scientific community and society at large.

10. Data protection provisions about the application and use of Facebook

On this website, IHPC has integrated components of the enterprise Facebook. Facebook is a social network. A social network is an online community that allows users to communicate and interact. Facebook allows its users to create private profiles, upload photos, and network through friend requests. The operating company of Facebook is Facebook, Inc., 1 Hacker Way, Menlo Park, CA 94025, United States. If a person lives outside of the United States or Canada, the controller is the Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.

With each visit to our website where a Facebook component has been integrated, the browser on the visitor's device is prompted to download the corresponding Facebook component. An overview of all the Facebook plugins can be found at https://developers.facebook.com/docs/plugins/. During this procedure, Facebook is informed of the specific sub-page of our website visited by the visitor.

If the visitor is logged into Facebook during the visit, Facebook is able to correlate the visit with the visitor's Facebook account. If the visitor interacts with our Facebook plugins, for example by clicking the "Like" button or leaving a comment, this information is sent directly to Facebook and stored there. If a visitor does not want this data to be transferred to Facebook, they must log out of their Facebook account before visiting our website.

Facebook's data protection guidelines, available at https://facebook.com/about/privacy/, provide more details about the collection, processing, and use of personal data by Facebook. It also explains the settings Facebook offers to protect the privacy of the individual. Moreover, various applications are available to prevent the transmission of data to Facebook. These applications can be used by the visitor to prevent data transmission to Facebook.

11. Data protection provisions about the application and use of LinkedIn

The Icelandic High Performance Computing National Competence Center has integrated components of LinkedIn Corporation on its website. LinkedIn is a web-based platform that facilitates networking for professionals. LinkedIn Corporation is based at 2029 Stierlin Court Mountain View, CA 94043, UNITED STATES. For users outside the United States, data privacy issues are overseen by LinkedIn Ireland, at Wilton Place, Dublin 2, Ireland.

When a visitor accesses a page of our website containing a LinkedIn plugin, their browser establishes a direct connection to LinkedIn servers, thereby informing LinkedIn of the specific page of our website being visited. If the visitor is logged into their LinkedIn account, this information can be linked to their profile. Interactions with the plugin, such as clicking the "Recommend" button, will also be stored by LinkedIn. To prevent LinkedIn from associating website visits with a LinkedIn profile, users should log out of their account before browsing the web. More information on LinkedIn's data protection provisions can be found at https://www.linkedin.com/legal/privacy-policy and https://www.linkedin.com/legal/cookie-policy.

12. Data protection provisions about the application and use of Twitter

‍The Icelandic High Performance Computing National Competence Center has also integrated Twitter components on its website. Twitter is a platform that allows users to share and broadcast short messages. The company operating Twitter is Twitter, Inc., located at 1355 Market Street, Suite 900, San Francisco, CA 94103, UNITED STATES.

Each time a visitor accesses a page on our website with a Twitter button, their browser connects directly to Twitter's servers, making Twitter aware of the specific page of our website the visitor is on. If the visitor is logged into their Twitter account, this visit can be linked to their Twitter profile. Any interaction with the Twitter plugins, like retweeting, will also be stored by Twitter. To prevent this, visitors should log out of their Twitter account before browsing the web. More details on Twitter's privacy policy can be found at https://twitter.com/privacy?lang=en.

13. Data protection provisions about the application and use of YouTube

The Icelandic High Performance Computing National Competence Center has incorporated components of YouTube on its website. YouTube is a widely recognized online video platform that permits content creators to upload videos, and users can view, rate, and comment on these videos without any charges. The platform encompasses a vast array of video types, from full-length movies and TV shows to music videos, trailers, and user-generated content.

YouTube's operational company is YouTube, LLC, located at 901 Cherry Ave., San Bruno, CA 94066, UNITED STATES. It's noteworthy to mention that YouTube, LLC operates under the umbrella of Google Inc., whose address is 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, UNITED STATES.

Each time a visitor lands on a page of our website containing a YouTube plugin, their browser establishes a direct connection to YouTube servers. This process informs YouTube about the specific page of our website the user is currently viewing. Further details on YouTube can be found at https://www.youtube.com/yt/about/en/. Throughout this automated process, both YouTube and Google gain insights into which particular sub-page of our website is being accessed by the visitor.

If a visitor is concurrently logged into their YouTube account, YouTube can correlate their website visit with their account if they view a page that houses a YouTube video. This data is then aggregated by YouTube and Google and linked to the visitor's personal YouTube account.

Both YouTube and Google obtain data via the YouTube component whenever a visitor accesses our website, provided they are logged into YouTube simultaneously. This data transfer happens irrespective of whether the visitor engages with a YouTube video. To prevent this automatic data transfer, visitors should log out of their YouTube account before navigating our site.

For an exhaustive understanding of how YouTube handles data, one can refer to their privacy policy at https://www.google.com/intl/en/policies/privacy/, which delineates the processes of data collection, utilization, and protection undertaken by YouTube and Google.

16. Duration for which the personal data will be retained

The guiding principle for the retention duration of personal data is the applicable statutory retention timeframe. Once this timeframe lapses, the relevant data is routinely purged unless it's crucial for the execution or commencement of a contract.

17. Stipulation of personal data as a legal or contractual mandate; Necessity for contract initiation; Data subject's obligation to furnish personal data; potential repercussions of not supplying such data

It's important to highlight that certain personal data provision is mandated by law (like tax directives) or might emerge from contract stipulations (such as details about the contractual party). At times, for the successful formation of a contract, it's imperative for the data subject to provide the Icelandic High Performance Computing National Competence Center with specific personal data that we subsequently need to process. For instance, if the data subject enters into a contract with IHPC, they are bound to provide us with the requisite personal data. If this data is not supplied, it could result in the inability to finalize the contract. Before the data subject provides any personal data, they should reach out to an IHPC representative. This representative will elucidate whether furnishing the personal data is a legal or contractual necessity, or a requirement crucial for the contract's formation, the binding nature of providing the personal data, and the possible implications of not doing so.

18. Presence of automated decision-making processes

‍At IHPC, we prioritize ethical and responsible operations. As such, we refrain from employing automated decision-making or profiling techniques.

19. Revisions to the Privacy Statement

The Privacy Statement of IHPC may undergo periodic modifications. Any changes to the statement will be promptly posted on our website. Such updates become binding once they're available on our platform. Hence, we recommend frequent visits to our site to stay updated on any modifications.

This Privacy Statement was crafted with the assistance of the Privacy Policy Generator of the External Data Protection Officers and was further refined in collaboration with RC GmbH, specializing in pre-owned notebooks, and the Media Law Specialists from WBS-LAW