PRIVACY POLICY

At LU-CIX, we take privacy and confidentiality matters very seriously. We have developed this Privacy Policy (the “Privacy Policy”) to clearly define our ongoing commitment to protecting privacy rights and to explain how we collect, use and disclose personal data when interacting with LU-CIX in the context of our websites www.lu-cix.lu, www.luxembourg-internet-days.com and https://datacenters-in-europe.com.

The Privacy Policy is issued by:

  • For the websites luxembourg-internet-days.com and https://datacenters-in-europe.com: LU-CIX ASBL, a non-profit organisation (association sans but lucratif) formed under the laws of Luxembourg with registered offices at 4, Rue A. Graham Bell, L-3235 Bettembourg, Grand Duchy of Luxembourg, registered within the Registre de Commerce et des Sociétés in Luxembourg under the number F7911; and

 

  • For the website lu-cix.lu: LU-CIX Management GIE, an economic interest group (groupement d’intérêt économique) formed under the laws of Luxembourg with registered offices at 4, Rue A. Graham Bell, L-3235 Bettembourg, Grand Duchy of Luxembourg, registered within the Registre de Commerce et des Sociétés in Luxembourg under the number C86;

 

(hereinafter “LU-CIX”, “us” or “our”, for either one or the other following entity depending on the concerned website).

Any processing is made by LU-CIX, which acts as data controller (i.e. the organisation which determines why and how to process personal data), within the meaning of and in accordance with applicable data protection laws, including but not limited to, the European General Data Protection Regulation 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.

In this Privacy Policy we use the following terms within the meaning of applicable data protection laws:

personal data” which means any information allowing the direct or indirect identification of an individual natural person;

processing” which means any act made in relation to such data (e.g. collecting, storing, and transferring data);

data subjects”, “you” and “your” refer to any individual using our websites and/or our services provided through our websites and any other third party being individuals on whom we may collect personal data.

 

1. COLLECTION OF PERSONAL DATA

When do we collect personal data? We will notably collect personal data:

  • When you navigate through our websites and therefore when you use our services;
  • When you request that we contact you to answer any of your questions including on technical and support related issues;
  • When you download material such as documents and videos;
  • When you apply to become a member, sponsor, joining company or a speaker notably via our registration forms;
  • When you log in to our services;
  • When you participate to or attend events referenced in our websites.

Important note. Most of the time we collect personal data directly from the data subject. Should you provide information, including personal data, on behalf of a third party individual (e.g. one of your employees), you undertake to do so in compliance with applicable data protection laws and in particular, to inform this third party of such processing and to provide him/her with this Privacy Policy.

Update of personal data. We will endeavour to keep the personal data in our possession or control accurate. Data subjects providing personal data are however responsible for promptly informing us of any change to their personal data.

Refusal to provide your personal data. You have the right to refuse to provide us with your personal data but you are aware that not providing us with some specific personal data (e.g. data requested for contacting us) would unfortunately prevent LU-CIX from answering to you, from providing you with our services, or from entering into an agreement or maintaining the related ongoing agreement with you.

 

2. TYPES OF PERSONAL DATA

We aim to be transparent about what we process and why. We request that you provide us with personal data that is only necessary for us to carry out our services in the context of the related website, such as the following types of personal data but not limited to:

  • identification information, such as your first name, your last name and your picture;
  • contact information, such as e-mail address, phone number, address, postal code, city and country of residence;
  • business-related information such as company you work for or represent, role, position and country of work;
  • record of your correspondence including e-mail address;
  • types of services or product received or purchased;
  • IT-related information, such as your IP address, the name of your internet service provider, the operating system and the browser you used, the date and duration of your visit, the name(s) of the visited page(s), personal data contained in cookies as the case may be and your login information;
  • financial and banking information such as for payment of membership’s fees;
  • your relationship with us such as your membership, your sponsorship and your inclusion in our connected network and your status of joining company or your role of speaker during our events; and
  • any other type of personal data related to the conduct of LU-CIX’s business.

 

Cookies. A cookie is a small file stored on the hard drive of your computer or in your browser memory, when you visit our websites. LU-CIX uses cookies that may contain personal data as the case may be. Use of cookies helps us to improve our websites and to deliver a better and more personalized service by enabling us to, for example: (i) estimate our audience size and usage patterns; (ii) save your password, store information about your preferences, allowing us to customize our websites according to your individual interests; and (iii) recognize you when you return to our websites and know what parts of the websites you visit, your preferences and what is most relevant to you. We may use the following types of cookies on our websites:

– session cookies, which last only for the duration of your visit (e.g. these enable us to identify that the same person is moving from page to page. We store and collect a unique ID to track your session from page to page via session cookies);

– persistent cookies, which last beyond your session (e.g. these enable us to offer you an enhanced user experience when you return to our websites).

Most browsers are initially set up to accept cookies. However, you can reset your browser to refuse all cookies or indicate when a cookie is being sent. You will need to consult the help area of your browser application for instructions. If you choose to disable your cookies setting or refuse to accept a cookie, some parts of our websites will not function properly or may be considerably slower. Unless you have adjusted your browser setting so that it will refuse cookies, your system will continue to accept cookies when you direct your browser to our websites. Accepting cookies means that you permit communication between your computer and our websites as described in this section.

We may also use cookies implemented by Google Analytics, which is a third party, to monitor and analyse the use of our websites for non-nominative statistics purposes. Google Analytics is a web analytic service offered by Google that tracks and reports websites traffic. This data is shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its own advertising network. We may also transmit such data to our sponsors as the case may be.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: http://www.google.com/intl/en/policies/privacy/.

You are free to consent or not to the use of these third party cookies through a banner that will appear on your screen.

 

3. LEGAL BASIS AND PURPOSES OF THE PROCESSING

In most cases, personal data will be processed for at least one of the following:

  • it is necessary for LU-CIX to take measures at your request prior to entering into a contract or for the performance of any contractual obligations towards you;
  • you have given prior consent to the processing of your personal data and your consent has been obtained pursuant to applicable laws, such as to receive commercial communications from us or third parties or for us to use third party cookies;
  • it is necessary for LU-CIX to be able to perform an obligation according to law or any decision by a public authority, such as to allow us to comply with applicable commercial laws and any regulatory obligations and to respond to requests and comply with requirements from public authorities; or
  • it is necessary for the purposes of the legitimate interest pursued by us or by a third party, (i) in the context of the websites such as to answer any queries from you or to provide requested services, to provide you with newsletters and other commercial communications in compliance with applicable laws, to provide you with information about LU-CIX, its products and services that might be of interest to you or at your request, to manage other requests (e.g. to attend an event) or to notify you about any changes to our services, to conduct surveys and make statistics, to present our websites and its contents in a suitable and effective manner for you, to use the cookies in relation to our websites, to enforce our Terms of Use and other agreements to improve your experience through the websites and (ii) outside the context of the websites browsing such as to provide our services, to manage our relationships with our suppliers, services provider and subcontractors as well as to prevent fraud, manage litigation and to protect the rights, property, or safety of LU-CIX and its affiliates.

No automated decisions will be made in relation to the personal data processed.

 

4. DISCLOSURE OF PERSONAL DATA

To achieve the above purposes, we may disclose personal data to the following recipients: other entities members of LU-CIX Group, our commercial partners, members, sponsors, clients, external services providers, subcontractors, third parties to which we provide services, professional advisors, purchasers or sellers of our assets and entities linked to LU-CIX if any, as well as public organisations, administrative or legal authorities and supervisory bodies if applicable.

Transfer of personal data. You are informed that certain recipients may be located outside the territory of the European Economic Area in countries that do not offer a level of protection equivalent to the one granted in the European Union. Any personal data transfer to such recipients will, depending on the nature of the transfer:

  • be covered by appropriate safeguards such as standard contractual clauses approved by the European Commission, in which case you may obtain a copy by contacting us; or
  • be otherwise authorised under data protection law, as the case may be, as such transfer is necessary for the performance or execution of a contract concluded in your interest or for the establishment, exercise or defence of legal claims or for the performance of a contract between you and us.

 

5. RETENTION

LU-CIX will store your personal data only for as long as necessary for the relevant processing activity to be completed and/or for the retention period permitted under applicable law.

 

6. YOUR RIGHTS

In relation to your personal data, you have the right to:

  • access the personal data held about you and receive additional information about how it is processed;
  • rectify or complete any inaccurate or incomplete personal data;
  • seek the erasure of your personal data when its processing is no longer necessary for the purposes described above, when the processing is not or no longer lawful for any reasons, when you have withdrawn your consent to the processing according to applicable laws, when the erasure is necessary to comply with applicable laws or when you object to the processing in the absence of any overriding legitimate ground for such processing;
  • object, on grounds relating to your particular situation, to any processing based on LU-CIX’s legitimate interest;
  • receive your personal data and transmit it to another data controller to the extent that the legitimacy of the processing lies on contractual performance and is carried out by automated means;
  • withdraw any consent given to the processing at any time to the extent that your consent justified such processing; and
  • seek the restriction of the processing, for instance, when you contest the accuracy of the personal data or when the processing is not or no longer compliant with the exception of storage, only processed in specific cases (e.g. for the establishment, exercise or defence of LU-CIX’s legal claims).

LU-CIX will respond to individual complaints and questions relating to privacy and will investigate and attempt to resolve all complaints. We will only be able to answer favourably to any of the above requests related to the right to oppose, right of erasure and right of restriction provided that it does not interfere with or contradict a legal obligation of LU-CIX (e.g. legal obligation to keep the related personal data) or due to any other impediment that would justify that LU-CIX would not be able to grant such requests. LU-CIX undertakes to handle each request free of charge and within a reasonable timeframe (in any case no longer than 1 month).

You may also lodge a complaint with the data protection authority in Luxembourg, the Commission Nationale pour la Protection des Données (the “CNPD”), or with your local data protection authority if you do not reside in Luxembourg. The CNPD can be contacted as follows:

– Telephone: (+352) 26 10 60 – 1

– Website: https://cnpd.public.lu/en.html

– Web-form: https://cnpd.public.lu/en/particuliers/faire-valoir/formulaire-plainte.html

– Address: 1, avenue du Rock’n’Roll, L-4361 Esch-sur-Alzette, Luxembourg

 

7. TECHNICAL AND ORGANIZATIONAL SECURITY MEASURES

Ensuring that personal data is appropriately protected from data breaches is a top priority for LU-CIX. We implement adequate technical and organizational security measures, such as, depending on the equipment, password protection, physical locks, etc., to ensure a level of security appropriate to the risks represented by the processing and the nature of the personal data to be protected.

Access to personal data is permitted to employees for the sole purpose of performing their professional duties. They are subject to a confidential obligation and are notably provided with training and documentation in order to improve their practical skills and knowledges on data protection issues.

 

8. AMENDMENT

LU-CIX reserves the right to change, supplement and/or amend this Privacy Policy at any time. In such case, notification will be given to you by email, or any other methods chosen by us and allowed under applicable law.

 

9. CONTACT AND EXERCISE OF YOUR RIGHTS

For any question or for exercising your rights in relation to this Privacy Policy, please use the following email address:
data-protection[at]lu-cix[dot]lu