Privacy Policy

The Controversy Generator collects short survey responses to opinion statements and pairs participants with differing viewpoints, to support structured discussion in classrooms and organisations.

Controller

The controller within the meaning of Art. 4(7) GDPR is
Urs Müller, Gotenstr. 21, 10829 Berlin, Germany — info@controversygenerator.org.

Who is responsible for what. For educator and administrator accounts, for security and abuse prevention, and for the anonymised, aggregated analysis dataset, we are the controller. Where an institution has contracted us to run this tool for its own programme, the institution is the controller for the identifiable data of that cohort, and we process it on the institution's behalf (Art. 28 GDPR). In practice: for a request concerning your cohort's identifiable data, please approach your educator or institution first; for anything concerning accounts, security or the aggregate dataset, contact us. We assist the institution in answering requests in either case (Art. 28(3)(e) GDPR).

Data protection officer: no data protection officer is appointed. § 38 BDSG has three separate triggers and we have assessed all three: headcount (at least 20 persons constantly engaged in automated processing — this service is operated by one person), processing that requires a data protection impact assessment under Art. 35 GDPR, and commercial processing for the purpose of transfer, anonymised transfer, or market or opinion research. The last two apply regardless of headcount. Our assessment is recorded in DPIA-DETERMINATION.md and is revisited whenever the scope or purpose of processing changes — in particular if cross-class research use becomes a purpose in its own right rather than support for the individual course.

What data we process

From survey participants

• Name or username — as entered by you; a pseudonym is fine.
• E-mail address — optional unless your educator turns it on for a particular survey, in which case it is required to submit. Each survey says which applies.
• Survey code — attributes your response to the correct survey.
• Survey responses — your answers to the opinion statements, stored as numerical values. Depending on the statements chosen by your educator, your answers can reveal personal views.
• Submission timestamp.

From educators and administrators

• E-mail address — for backoffice sign-in.
• Password — stored only as a bcrypt hash.
• Survey data — titles, items and settings of surveys you create.

Legal bases

• Running the survey and pairing discussion partners — Art. 6(1)(f) GDPR, our legitimate interest in supporting the educational programme in which participants take part.
• Educator and administrator accounts — Art. 6(1)(b) GDPR, performance of the arrangement under which the account was created.
• Security, rate-limiting and abuse prevention — Art. 6(1)(f) GDPR, our legitimate interest in operating the service securely.

Recipients and third-country transfers

We use no third parties for advertising, analytics or tracking, and we do not sell or share personal data for marketing purposes. The following providers process data on our behalf as processors under a data processing agreement pursuant to Art. 28 GDPR:

• IONOS SE (Germany) — hosting and outgoing e-mail.
• Microsoft Ireland Operations Ltd. (OneDrive) — storage of the weekly off-site backup copies. Those backups are encrypted before they leave the server, and the private key exists only on the operator's own machine — never at the provider. So Microsoft holds ciphertext it cannot read.
• healthchecks.io — monitoring that the backup run happened. Only status pings are sent ("run succeeded / failed"); no content and no participant data.

Transfers outside the EU/EEA: processing takes place in the EU; the servers and databases are in Germany. Two things are worth stating in full. Microsoft (OneDrive) provides for transfers outside the EEA under Art. 46 GDPR safeguards (EU standard contractual clauses) — what reaches it is only the backup copies, encrypted before they leave the server, whose key we do not hand over. And healthchecks.io runs infrastructure in the EU and the US, but receives only backup-run status pings: no participant data and no content.

What this means for erasure: when a record is deleted, a copy may remain inside backups until those expire: up to 14 days in the backups held on the server, and up to 30 days in the encrypted off-site copies. Backups are used only to restore the service after a failure, never for ordinary processing.

How long we keep data

• Automatic anonymisation: surveys older than 12 months are anonymised automatically — names and e-mail addresses are removed; numerical responses are kept for aggregate analysis. A daily job enforces this.
• Educator reminders: educators are prompted to review surveys inactive for 30 days or more.
• Manual deletion: educators and administrators can delete whole surveys or individual submissions at any time.

Who can see your data

• Educators see participant names, e-mail addresses (where provided) and responses for their own surveys only.
• The administrator has technical access for maintenance and security purposes only.

Data security

• The server is located in Germany.
• All transmission is encrypted using HTTPS/TLS.
• Passwords are stored only as bcrypt hashes, never in plain text.
• Session cookies are signed and HTTP-only.
• Web fonts are served from our own server — no third-party CDNs, so no data flows to third parties when fonts load.
• IP addresses processed for rate-limiting are held in memory only and never written to the database.

Server log files

Our web server records standard access log entries: IP address, date and time, the resource requested, HTTP status, referrer and browser identifier. These logs are used solely to operate and secure the service, are not combined with other data, are not used to identify individuals or build profiles, and are rotated and deleted after 14 days. IP addresses processed for rate-limiting are held in memory only and never written to the database.

Your rights

You have the following rights:

• Access (Art. 15 GDPR) — what data we hold about you.
• Rectification (Art. 16 GDPR) — correction of inaccurate data.
• Erasure (Art. 17 GDPR) — deletion of your personal data.
• Restriction of processing (Art. 18 GDPR).
• Data portability (Art. 20 GDPR) — your data in a structured, machine-readable format.
• Withdrawal of consent (Art. 7(3) GDPR) — at any time, with effect for the future, as easily as it was given.

Response time. We aim to respond to enquiries promptly. Requests concerning your personal data are answered within the period required by Art. 12(3) GDPR (one month at the latest).

Erasure and withdrawal on this tool

Within a short window after submitting you can withdraw your response yourself using the withdrawal option on your confirmation page. After that, contact your educator (who can delete individual submissions) or write to us. Once a survey has been anonymised, responses are no longer linked to a person and can no longer be individually located.

Whether you must provide data

Providing data is neither a statutory nor a contractual requirement. A name (which may be a pseudonym) is needed to take part so that your educator can attribute responses. The e-mail address is optional by default; an educator can make it required for their own survey, and where they have, you cannot submit without it.

Supervisory authority

You also have the right to lodge a complaint with a data protection supervisory authority. The authority competent for our location is:

Berliner Beauftragte für Datenschutz und Informationsfreiheit
Alt-Moabit 59–61
10555 Berlin
Germany
www.datenschutz-berlin.de

Automated decision-making

No automated decision-making, including profiling, within the meaning of Art. 22 GDPR takes place.