RoomControl

Privacy Policy

This English translation is provided for convenience. Only the German version is legally binding: German version.

1. Data protection at a glance

General information

The following information provides a simple overview of what happens to your personal data when you visit this website. Personal data means any data by which you can be personally identified. For detailed information on the subject of data protection, please refer to the privacy policy set out below this text.

Data collection on this website

Who is responsible for data collection on this website?
Data processing on this website is carried out by the website operator. You can find the operator's contact details in the section "Information about the controller" in this privacy policy.

How do we collect your data?
On the one hand, your data is collected when you provide it to us. This may, for example, be data that you send to us by email. Other data is collected automatically by our hosting provider's IT systems when you visit the website. This is primarily technical data (e.g. internet browser, operating system or time of the page request). This data is collected automatically as soon as you enter this website.

What do we use your data for?
Some of the data is collected to ensure that the website is provided without errors and securely. Personal data that you actively send to us (e.g. by email) is used exclusively to process your inquiry.

What rights do you have regarding your data?
You have the right to receive information free of charge at any time about the origin, recipients and purpose of your stored personal data. You also have the right to request the rectification or erasure of this data. If you have given consent to data processing, you can withdraw this consent at any time with effect for the future. You also have the right to request the restriction of the processing of your personal data under certain circumstances. Furthermore, you have the right to lodge a complaint with the competent supervisory authority. You can contact us at any time about this and about any other questions on the subject of data protection.

Analytics and third-party tools

This website uses no tracking, advertising or recognition technologies and no third-party analytics tools. Your browsing behavior is not evaluated across websites and no profiles are created about you. For our interactive online demo, we only collect anonymous, aggregated usage statistics, without cookies and without personal data (see the section "Usage statistics for the online demo").

2. Hosting

We host the content of our website with the following provider:

External hosting

This website is hosted externally. The personal data collected on this website is stored on the host's servers. This may include, in particular, IP addresses, meta and communication data, website accesses and other data generated via a website.

External hosting is carried out in the interest of providing our online services securely, quickly and efficiently through a professional provider (Art. 6(1)(f) GDPR). Our host will only process your data to the extent necessary to fulfill its performance obligations and will follow our instructions with regard to this data. We use the following host:

netcup GmbH
Daimlerstraße 25
76185 Karlsruhe

Data processing agreement

We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is an agreement required by data protection law, which ensures that the provider processes the personal data of our website visitors only in accordance with our instructions and in compliance with the GDPR.

3. General information and mandatory disclosures

Data protection

The operators of this website take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with the statutory data protection regulations and this privacy policy.

When you use this website, various personal data is collected. Personal data is data by which you can be personally identified. This privacy policy explains what data we collect and what we use it for. It also explains how and for what purpose this is done.

We would like to point out that data transmission over the internet (e.g. when communicating by email) may be subject to security vulnerabilities. Complete protection of data against access by third parties is not possible.

Information about the controller

The controller for data processing on this website is:

RC RoomControl GmbH
Burgstraße 3
51515 Kürten

Phone: +49 2268 9003 6
Email: info@room-control.de

The controller is the natural or legal person who alone or jointly with others determines the purposes and means of the processing of personal data (e.g. names, email addresses or similar).

Storage period

Unless a more specific storage period is stated within this privacy policy, your personal data will remain with us until the purpose for the data processing no longer applies. If you assert a legitimate request for erasure or withdraw your consent to data processing, your data will be deleted unless we have other legally permissible reasons for storing your personal data (e.g. retention periods under tax or commercial law); in the latter case, the data will be deleted once these reasons no longer apply.

General information on the legal bases for data processing on this website

If you have consented to data processing, we process your personal data on the basis of Art. 6(1)(a) GDPR. Consent can be withdrawn at any time. If your data is required for the performance of a contract or for the implementation of pre-contractual measures, we process your data on the basis of Art. 6(1)(b) GDPR. Furthermore, we process your data, where it is required to fulfill a legal obligation, on the basis of Art. 6(1)(c) GDPR. Data processing may also be carried out on the basis of our legitimate interest under Art. 6(1)(f) GDPR.

Recipients of personal data

As part of our business activities, we work together with various external parties. In some cases, this also requires the transfer of personal data to these external parties. We only pass on personal data to external parties if this is necessary for the performance of a contract, if we are legally obliged to do so, if we have a legitimate interest in the transfer under Art. 6(1)(f) GDPR, or if another legal basis permits the transfer of the data. When using processors, we only pass on our customers' personal data on the basis of a valid data processing agreement.

Withdrawal of your consent to data processing

Many data processing operations are only possible with your express consent. You can withdraw consent you have already given at any time. The lawfulness of the data processing carried out before the withdrawal remains unaffected by the withdrawal.

Right to object to data collection in specific cases and to direct marketing (Art. 21 GDPR)

IF DATA PROCESSING IS CARRIED OUT ON THE BASIS OF ART. 6(1)(E) OR (F) GDPR, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME, ON GROUNDS RELATING TO YOUR PARTICULAR SITUATION, TO THE PROCESSING OF YOUR PERSONAL DATA; THIS ALSO APPLIES TO PROFILING BASED ON THESE PROVISIONS. IF YOU OBJECT, WE WILL NO LONGER PROCESS THE PERSONAL DATA CONCERNED UNLESS WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING WHICH OVERRIDE YOUR INTERESTS, RIGHTS AND FREEDOMS, OR THE PROCESSING SERVES THE ESTABLISHMENT, EXERCISE OR DEFENSE OF LEGAL CLAIMS (OBJECTION UNDER ART. 21(1) GDPR).

Right to lodge a complaint with the competent supervisory authority

In the event of violations of the GDPR, data subjects have the right to lodge a complaint with a supervisory authority, in particular in the Member State of their habitual residence, their place of work or the place of the alleged violation. The right to lodge a complaint exists without prejudice to any other administrative or judicial remedies.

Right to data portability

You have the right to have data that we process automatically on the basis of your consent or in performance of a contract handed over to you or to a third party in a commonly used, machine-readable format. If you request the direct transfer of the data to another controller, this will only be done to the extent technically feasible.

Access, rectification and erasure

Within the scope of the applicable statutory provisions, you have the right at any time to obtain information free of charge about your stored personal data, its origin and recipients and the purpose of the data processing and, where applicable, a right to rectification or erasure of this data. You can contact us at any time about this and about any other questions on the subject of personal data.

Right to restriction of processing

You have the right to request the restriction of the processing of your personal data. You can contact us at any time for this purpose. The right to restriction of processing exists in the following cases:

If you have restricted the processing of your personal data, this data may, apart from being stored, only be processed with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or a Member State.

SSL and TLS encryption

For security reasons and to protect the transmission of confidential content, this site uses SSL or TLS encryption. You can recognize an encrypted connection by the fact that the address line of the browser changes from "http://" to "https://" and by the lock symbol in your browser bar. When SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.

4. Data collection on this website

Cookies

This website does not use any cookies that require consent. No tracking, statistics or marketing cookies and no comparable third-party recognition technologies are set. For this reason, no cookie consent banner is required on this website.

You can also configure your browser so that you are informed when cookies are set, so that cookies are generally rejected, or so that cookies are automatically deleted when the browser is closed.

Server log files

The provider of this website automatically collects and stores information in so-called server log files, which your browser automatically transmits to us. These are:

This data is not merged with other data sources. This data is collected on the basis of Art. 6(1)(f) GDPR. The website operator has a legitimate interest in the technically error-free presentation and the optimization of the website; for this purpose, the server log files must be collected.

Contact forms

Contact forms are available on our website (general inquiry and "Report a problem"). When you submit such a form, the data you enter is transmitted to our server and forwarded from there by email to our mailbox. Depending on the form, this includes: name, educational institution (optional), email address and your message, or subject and problem description, as well as an optional image attachment (screenshot) if you attach one.

The transmission to our mailbox takes place over an encrypted connection (SMTP over TLS). Your details are used exclusively to process your inquiry and are not stored in a database; afterwards they are held as an email in our mailbox. To protect against automated misuse (spam), we check technical characteristics of the request when it is submitted (a hidden form field, the time taken to fill in the form and the origin of the request) and evaluate the message text for clear advertising characteristics (such as short-link services or typical spam keywords). If a request is classified as automated advertising, we hold it back and, in order to monitor these filters, log a short line containing the time, the reason, the IP address, the email address provided and a text excerpt. This log serves solely to identify genuine inquiries that were held back by mistake and is deleted after 30 days at the latest; the legal basis is our legitimate interest in preventing misuse (Art. 6(1)(f) GDPR). The data is not passed on to any other third parties.

The legal basis is Art. 6(1)(b) GDPR, provided your inquiry is related to the initiation or performance of a contract; otherwise, our legitimate interest in the effective processing of your inquiry (Art. 6(1)(f) GDPR) or your consent (Art. 6(1)(a) GDPR), where this was requested. The message we receive remains with us until you ask us to delete it or the purpose for storing it no longer applies; mandatory statutory retention periods remain unaffected.

Inquiries by email, phone or fax

If you contact us by email, phone or fax, your inquiry including all resulting personal data (name, inquiry) will be stored and processed by us for the purpose of handling your request. We do not pass on this data without your consent.

This data is processed on the basis of Art. 6(1)(b) GDPR, provided your inquiry is related to the performance of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective handling of the inquiries addressed to us (Art. 6(1)(f) GDPR) or on your consent (Art. 6(1)(a) GDPR), where this was requested; consent can be withdrawn at any time.

The data you send to us via contact requests remains with us until you ask us to delete it, withdraw your consent to its storage, or the purpose for the data storage no longer applies (e.g. after your request has been fully processed). Mandatory statutory provisions, in particular statutory retention periods, remain unaffected.

5. Usage statistics for the online demo

On our interactive online demo (room-control.de/demo, the demo interface is in German), we collect anonymous, aggregated usage statistics to understand how much the demo is used and which features are tried out, and to improve it.

Only anonymous events are processed (e.g. that a view was opened or a feature was tried out), together with the approximate time spent within a single visit. To group the events of a visit together, a random session identifier is used that exists only in your browser's memory and is not stored on your device.

We use no cookies for this and store no IP addresses and no personal data. The data is not and cannot be linked to you as a person. The data is processed exclusively on our own server, is not passed on to third parties and is deleted after twelve months at the latest.

Independently of these statistics, the demo only stores one technically necessary setting locally in your browser: whether the on-screen explanations are switched on or off. This setting is not used for analysis, contains no personal data and is not transmitted to us.

The legal basis is our legitimate interest in designing and improving our services in line with demand (Art. 6(1)(f) GDPR). Since the evaluation is exclusively anonymous and aggregated, no reference to any person exists.

6. The RoomControl software: what data leaves your school

Sections 1 to 5 cover this website. This section covers the RoomControl software, namely the school server, the teacher console and the RoomControl programs on your school's Windows PCs. It describes, as of version 1.6.4.1, what data the software transmits to RC RoomControl GmbH or sends via its servers. For older versions, the subsection "School servers and PCs before version 1.6.4.1" also applies. The software's connections to room-control.de and lizenz.room-control.de are encrypted with HTTPS. Apart from one event described below, which the teacher console sends when it cannot connect to the school server, the software sends no automatic error or crash reports, that is, no logs, error messages or memory dumps.

RC RoomControl GmbH is the controller for the processing of this data on our servers; the information about the controller and about your rights in section 3 applies. The legal bases and storage periods are set out in the last subsection.

At a glance

What stays in your school network

Exam files, exam results and their interim backups, files collected via the seating plan, screen sharing, the live images of the PCs, print jobs and sign-ins with the school accounts from your directory service stay in your school network. They only travel between the PCs, the teacher console, your school server and the services your school has set up for this purpose. The software transfers none of this content to us or to any cloud. There are two exceptions, both described below:

License check and licensing service

Each time it starts, the school server registers with our licensing service (lizenz.room-control.de). It transmits a device identifier, the product name, the host name the server runs under (for an installation as a Docker container, usually the container's internal ID) and the operating system version. The device identifier is a hash, that is a checksum, derived from the machine ID of the server computer or, failing that, from an identifier generated once at random. After that, the school server checks the license status every minute and sends only the device identifier. No license key, no version number and no data about people, exams or rooms are transmitted. In return, the school server receives the license status and the customer name we have on file, usually the name of your school. The license check cannot be switched off.

For each school server, the licensing service stores the device identifier, the product name, the host name, the operating system version, the times of the first and last contact, the most recently used public IP address, the license status with the end date of a trial period, and a note. In addition, for each IP address from which requests were received, it stores the first and last contact from that address and the number of requests. As long as the school server keeps connecting, the licensing service deletes those of its addresses from which no request has been received for 30 days; the most recently used address remains on the school server's record. If the school server stops connecting, for example because it has been shut down or the software has been removed, all stored addresses remain. The licensing service does not delete the record or these addresses by itself, only when we delete the installation in the licensing service.

The IP addresses serve two purposes. First, the licensing service uses them to detect copied installations: if the same device identifier connects from several IP addresses within a few minutes, it records a suspicion. Second, the free trial period is tied to the public IP address: if a new installation connects from the same address from which an installation in its trial period last connected, it adopts that installation's end date (the latest one if there are several), where applicable with a minimum period (details in the license terms, in German). In both cases the IP addresses concerned are also recorded in the note on the installation or in the log.

The licensing service keeps a log recording the first registration of each school server with its IP address, device identifier, product name, host name, trial end date and note, as well as each minimum period granted with its IP address and each suspected copied installation with the IP addresses involved. This log is currently not deleted automatically. The licensing service needs the entries on minimum periods for 365 days, because it grants at most three minimum periods per IP address within 365 days. The licensing service also writes the same events, including the IP address, to its operating log. We back up the licensing service's database regularly; the last 30 backups are kept on the server. At least once a month, we retrieve an encrypted copy of the backups to a computer outside the server.

The server for lizenz.room-control.de is operated for us by netcup GmbH (see section 2). Our data processing agreement with netcup GmbH also covers this server. No separate limit on the storage period is configured for the licensing service's operating log. We delete this data as soon as it is no longer needed for the stated purpose and review the stored data at least once a year.

Usage statistics of the software

Unlike the statistics of the online demo (section 5), these events can be attributed to your school and to individual devices. For usage statistics, the school server immediately sends a single event to room-control.de for the following actions:

It also reports when a PC cannot apply a program lock.

Each event contains a school name, namely the customer name we have stored for your school server in our license management or, as long as we have not stored one, "Musterschule" (sample school). It also contains the computer name of the teacher PC on which the action was triggered, the console and server versions, a timestamp and details of the action. If a PC cannot apply a program lock, the event contains that PC's computer name instead. The details are fixed texts, counts and settings, for example the number of PCs involved, the number and total size of the exam files, the number of programs with internet access or whether software restrictions are active. When exam results are retrieved, the number of participants with and without a submission, the number and size of the submitted files and of the interim backups, further counts about these files and the file extensions of the submitted files are added. Only common extensions from a fixed list are named; all others are grouped together. Instead of its name, each exam carries an identifier generated at random when it is created, which cannot be traced back to the name. For issue reports, only the type (IT or facilities), the category and the selected recipient group (internal, IT service provider or both) are transmitted.

The events contain no names of people, exams, rooms, files or programs as separate details. Computer names, however, are transmitted in plain text. If they follow a room or personal naming scheme at your school (such as "R101-PC07" or a teacher's name), the events can be attributed to rooms or people through them.

Independently of the school server, the Windows PCs themselves send two kinds of events to room-control.de. The RoomControl service, which runs in the background on every PC with RoomControl, reports the computer name, the installed version, the operating system, the amount of RAM and the processor type each time it starts, which in practice means each time a student or teacher PC boots. The teacher console reports its computer name and version when it cannot connect to the school server. These two events do not contain the school name. The Windows PCs send no further statistics.

For each event we store the event type, school name, computer name, version, time and the details of the action. For the start-up reports of the Windows PCs, only the latest state per computer name is kept. Our server only accepts the details intended for each event type and discards everything else. No IP address is stored in the statistics. As with every request to this website, however, the web server records server log files with the IP address the request comes from (section 4, "Server log files"). The statistics are currently not deleted automatically.

Switching it off: Usage statistics are switched on by default, including in the app from the Univention App Center. From version 1.6.4.1, your IT administrators can switch off the school server's events. If the server runs as an app from the Univention App Center, only the usage statistics setting applies, which is offered during installation and later in the app settings; there it takes precedence over the server configuration. For other installations, your IT administrators set "TelemetryEnabled" to "false" in the server configuration (the file config.json in the server's data folder). The change takes effect without a restart. If the setting is missing, the default applies, so the statistics are switched on. The switch does not affect the two events from the Windows PCs, for which there is currently no switch, nor the license check, the retrieval of updates and news, report emails or "Problem melden".

School servers and PCs before version 1.6.4.1

The information on usage statistics in this section applies from version 1.6.4.1. School servers, Windows PCs and teacher consoles running older versions send further details until they are updated:

The school server of the app from the Univention App Center has at least version 1.6.4.1. Windows PCs with older versions may still exist there, for example if they were set up with an older installation package.

Updates and news

On every Windows PC with RoomControl, an update service checks whether a new version is available about two minutes after start-up and then every six hours by default, or after five minutes if an attempt fails. From version 1.6.4.1, it first asks your school server, provided the server offers updates. If the school server offers no updates or the update service cannot reach it, it asks room-control.de. When needed, it downloads the installation package from one of these two sources. Each time it is opened, the teacher console retrieves the current news from room-control.de once. Which news items have been read is stored only in the teacher's Windows profile. The changelog and the manual only open in the browser when clicked.

These requests send no identifiers or other details. For technical reasons, our server receives the IP address the request comes from; what section 4 says under "Server log files" applies to it. Your IT administrators can switch off update checks per PC or via group policy by setting the registry value "UpdaterEnabled" (DWORD) to 0 under HKLM\SOFTWARE\RoomControl. The value takes effect the next time the update service starts, at the latest after the PC is restarted. The PC then no longer checks for updates and downloads no new versions. A package that the update service had already downloaded before it was switched off is still installed; beyond that, the PC only receives new RoomControl versions if your IT administrators distribute them themselves. There is no switch for retrieving the news.

Your IT administrators update the school server. For an installation with Docker, the server computer downloads the image from Docker Hub (Docker Inc.) using access credentials provided by us, automatically every night if desired. If the server runs as an app from the Univention App Center, the image comes from Univention. By default, the UCS server installs new versions of the app by itself every night through the App Center; this automatic update can be switched off in the app settings. For an installation on Windows, your IT administrators replace the program files. The privacy notices of Docker Inc. and Univention apply to these downloads.

Installation through the Univention App Center

If the school server is installed as an app from the Univention App Center, the privacy notices of Univention GmbH, which operates the App Center, apply to registering there and downloading the app. According to Univention's description, administrators of a UCS server have to register with a valid email address in order to use the App Center, and the App Center informs them that the provider of an app may contact them.

For RoomControl we have switched on the installation notification. According to its own description, Univention then informs us daily about who installed the app. The notification is sent to info@room-control.de. We do not currently know exactly which details it contains or whether uninstallations are reported as well. We use the notification to contact schools that have installed RoomControl about the trial period, licensing and important notices. There is no fixed storage period for the notifications.

Issue reporting

When your school's IT coordinators approve a report, the report email is not sent through your school's mail server. The school server hands it over to room-control.de via HTTPS, and our server sends it from an email account of RC RoomControl GmbH to the recipients your school has entered in the issue reporting configuration. We use the mail server of IONOS SE to send these emails (see "Service providers"). This also applies to internal reports to the school's IT administrator and the custodian. Simply creating a report does not send an email. The email is delivered to the recipients as an ordinary email. Whether it is encrypted on the way depends on the mail servers involved.

In the app from the Univention App Center, issue reporting is switched off by default. In other installations it is switched on, but only sends emails once your school has entered recipients.

A report email contains:

The names of the users signed in on the PCs appear as a separate column only in emails that go exclusively to recipients within the school. The seating plan image, however, shows the room as the console displays it at the time of reporting, in every email, including emails to external recipients:

Attached images can show any content.

Our server does not store the content of the emails. To limit requests, it keeps the requesting IP address in hashed but not anonymized form, together with the times of the most recent requests; it currently does not delete these files by itself. Issue reporting can be switched off in the server configuration or, when the server runs as an app from the Univention App Center, in the app settings. If no recipients are entered, no email is sent.

"Problem melden" (report a problem) in the teacher console

This section concerns the function in the software, not the "Report a problem" form on this website. With "Problem melden", teachers send us a support request from the console. It is only sent when the subject, name, school and description have been filled in and the teacher clicks "Senden" (send). The request goes via HTTPS to room-control.de and from there via the IONOS mail server to our mailbox support@room-control.de. If an email address is entered, it is only used as the reply-to address.

The following is transmitted: the name entered, the school entered, the subject and description, the teacher's Windows user name, the computer name of the teacher PC, and the date and time. The console also tries to attach the log files of the RoomControl programs on this PC (console, RoomControl service and, if present, the student program) as a ZIP archive. The log folder of the service and the student program can only be read by administrators. If the console cannot read it, which is the usual case when it runs without administrator rights, the request is sent without any attachment.

In addition, with the same click the school server sends its log files covering up to the last 14 days as a ZIP archive to support@room-control.de. These logs can contain the full names of teachers and exam participants, exam names, roles, computer names and MAC addresses, for example who opened the console and which participants did not submit anything. Any teacher can trigger this. The usage statistics setting has no effect here. Here, too, our server keeps the requesting IP address in hashed but not anonymized form, together with the times of the most recent requests, to limit requests. There is no fixed storage period for the support requests and the attached log files in our mailbox.

Service providers

Legal bases and storage periods

The following legal bases apply to the processing on our servers for which RC RoomControl GmbH is the controller (section 3, "Information about the controller"):

Storage period for each data set:

For data that is not deleted automatically or for which there is no fixed period, the following applies: We delete this data as soon as it is no longer needed for the stated purpose and review the stored data at least once a year.

Source: e-recht24.de (adapted)