Privacy Policy

Русская версия

Thank you for visiting Luxtoday.

We comply with «Regulation (EU) 2016/679 of the European Parliament and of the Council 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, and repealing Directive 95/46/EC (General Data Protection Regulation)» or GDPR. When processing personal data, we adhere to the principles set forth in Article 5 of the GDPR.

Our Privacy Policy is designed to provide transparency into our privacy practices and principles. Please read this Privacy Policy (hereinafter referred to as the «Privacy Policy») carefully, in order to understand the purposes for which we process your personal data, as well as how you can exercise your rights regarding your personal data that is processed by Luxtoday.

If you have any questions regarding the processing of your personal data or the protection of your personal data, or any suggestions on how to improve the wording of this Privacy Policy, or if you would like to review the officially approved version, please send us a message using the contact information in Section 9 «Contacts».

1. Scope of use

This Privacy Policy is designed to inform you about how we collect and process your personal data when you use our information resources, during the course of our journalistic activity and for the purpose of organising various events.

This Privacy Policy applies to the processes outlined in Section 3 «Privacy notice».

Please note that our information resources may contain links to the resources of other service providers that are beyond our control and to whom this Privacy Policy does not apply.

We require that our partners handle user data with care, therefore, we work only with companies that have established their credibility.

2. The data we collect

We may collect the data listed below in connection with your use of the Luxtoday. We want to provide you with the most comprehensive information on all the data we process when you use Luxtoday. We collect information when you use our Site or register on it. Login to the site or registration means the user’s consent to the collection of information.

2.1 Information we collect when you use

During each of your visits to Luxtoday, we may collect the following data: 

  • Data about the devices, networks and platforms you use: identifier of the device you are using (IP address, Apple ID, Android ID, etc.), connection data (date, time, duration), type and version of the browser software (Internet Explorer, Safari, Mozilla Firefox, Google Chrome, etc.), type of operating system (Microsoft Windows, Apple OS, Linux, Unix, etc.).
  • Data about your preferences and other actions on the platform: interface language, reference of the user’s start page. 
  • Data relating to your browsing: route on the pages and duration of consultation of certain pages, content that you consult, searches and results of searches and generally your actions on the site.
  • Information on the reading or not of the emails we send you and on your clicks on the links contained in these emails.

To collect some of the data listed above, we may use cookies. For more information on the use of cookies, see Section 4 below.

2.2. Collecting the personal data of underage users

Our information resources are not designed to process the personal data of children below the age of 13. In the event that we need to use this type of data to create website content, it is mandatory that we request consent from a parent or legal guardian.

If you have reason to believe that a child has provided us with his or her personal data, please let us know using the contact information in Section 9 «Contacts».

3. Privacy notice

3.1.Processing your personal data through Luxtoday information resources with identification

The Luxtoday’s information resources process personal data to identify you as an individual for the following purposes:

3.1.1. To provide you with the features that are available in your personal account on Luxtoday website

Purpose of personal data processing:

To provide you with the opportunity to participate in discussions on news and commentary.

Personal data processed for this purpose:

Your name or username and email are necessary to create a personal account on Luxtoday website.

Once you have created an account, you can add more information to your personal account, including a profile photo, age, gender, date of birth, country and social media contacts. This additional information is not required.

If you provide your social media ID, Luxtoday website will process the data available on your social media accounts, including your first and last name, profile photo, date of birth, gender, email and subscriptions.

Legal grounds for processing your personal data:

Your consent.

Period of storage of your personal data:

Until you delete your account or withdraw your consent (or request that we delete your data).

The withdrawal of consent procedure is described in Clause 5.7 «Right to withdraw consent».

Transferring personal data to third parties

If you provided social media ID via your personal account settings, your data will be transferred to third parties, specifically: Facebook Inc. (Facebook); Google LLC (Firebase, Google Analytics); Twitter Inc. (Twitter); and Vkontakte LLC (Vkontakte).

No data will be transferred to third parties if you do not provide your social media accounts via your personal account settings.

Transferring personal data to third countries and international organisations

If you provide your social media accounts via your personal account settings, your personal data will be processed in countries where the respective social media providers operate.

If you do not provide social media ID via your personal account settings, your personal data will only be processed in the Luxemburg.

3.1.2.To organise contests and other events

Purpose of personal data processing

To organise contests or campaigns for marketing purposes.

Personal data processed for this purpose

Social media ID, first name, last name, patronymic (middle name), age, country, contacts for messenger sites and social media, contact telephone numbers, email, photos and videos.

Legal grounds for processing your personal data

The rules of participation for the contest or other event.

Period of storage of your personal data

Until the end of the event.

Winners’ data are subject to processing until they receive their awards.

Transferring personal data to third parties

If third parties (partners, third-party platforms) are involved in organising the event or presenting awards (postal services, courier services or partners), your personal data will be transferred to third parties.

If no third parties are involved in organising any stage of the contest, including the presentation of awards to winners, the Luxtoday will not transfer any personal data to third parties.

Transferring personal data to third countries and international organisations

If third parties (partners, third-party platforms) are involved in organising the event or presenting awards (postal services, courier services or partners), your personal data will be processed in the Luxemburg and in other countries where these third parties operate.

If no third parties are involved, your personal data will only be processed in the Luxemburg.

3.1.3 To comment on news via social media accounts

Purpose of personal data processing

To provide users with the opportunity to comment on news content on Luxtoday website using their Facebook accounts.

Personal data processed for this purpose

Facebook ID, first name, last name, profile photo.

Legal grounds for processing your personal data

Your consent.

When a user comments on our news content, information about the author of this comment becomes publicly available unless it violates the user’s rights and/or freedoms. We expect the author to be aware of this.

Period of storage of your personal data

Your personal data will be stored until you withdraw your consent.

The withdrawal of consent procedure is described in Clause 5.7 «Right to withdraw consent».

Transferring personal data to third parties

Facebook Inc. (Facebook).

Transferring personal data to third countries and international organisations

Your personal data will be processed in Luxemburg and other countries where the social media provider operates.

3.1.4. Email newsletters to Luxtoday subscribers

Purpose of personal data processing

To distribute email newsletters.

Personal data processed for this purpose

First name, last name, email, your location (address), email client.

Legal grounds for processing your personal data

Your consent.

Period of storage of your personal data

Until you withdraw your consent.

The withdrawal of consent procedure is described in Clause 5.7 «Right to withdraw consent».

Transferring personal data to third parties

The Rocket Science Group (Mailchimp); SendPulse Inc. (Sendpulse).

Transferring personal data to third countries and international organisations

Your personal data will be processed in the Luxemburg, Germany, Lithuania and in other countries where these third parties operate.

3.1.5.Feedback

Purpose of personal data processing

To process requests or comments (complaints and suggestions) from individuals or representatives of organisations.

Personal data processed for this purpose

First name, last name; place of employment and job title; address; country; contact telephone numbers; email.

Legal grounds for processing your personal data

Ensuring you receive feedback to resolve your issue.

Period of storage of your personal data

Until your issue is resolved.

Transferring personal data to third parties

No data is transferred to third parties.

Transferring personal data to third countries and international organisations

Your personal data will only be processed in Luxemburg.

3.2.Processing your personal data through Luxtoday information resources without identification

Our information resources automatically collect data without identifying you as an individual for the following purposes:

3.2.1. User behaviour analysis for Luxtoday using internal analytics systems

Purpose of personal data processing

To improve website performance and content delivery, to identify the most relevant news content, to display targeted advertising on the Luxtoday’s website and in advertising networks.

Personal data processed for this purpose

Cookies, IP address, location, type and version of the device’s operating system, type and version of browser, type of device and screen resolution, source of traffic (website or ad), language of the operating system and browser, user’s online activity.

Legal grounds for processing your personal data

Legitimate interest.

When processing your data, we act based on our legitimate interest because no other grounds apply in this case. Our performance depends on your interest in the content we provide and on ease of use.

User behaviour analysis is a common practice among media outlets, therefore, we expect you to be aware of this. We assure you that any analysis of your data that we conduct to achieve the said goal will have no significant impact on your rights and freedoms.

Period of storage of your personal data

The period of storage depends on the type of cookie.

Transferring personal data to third parties

No personal data is transferred to third parties.

Transferring personal data to third countries and international organisations

Your personal data will only be processed in Luxemburg.

3.2.2. User behaviour analysis for Luxtodayusing third-party resources

Purpose of personal data processing

To improve website performance and content delivery, to show the most relevant news content, to display targeted advertising.

Personal data processed for this purpose

Cookies, IP address, location, type and version of the device’s operating system, type and version of browser, type of device and the screen resolution, source of traffic (website or ad), language of the operating system and browser, user’s online activity.

Legal grounds for processing your personal data

Your consent.

Period of storage of your personal data

  • until the expiration of the storage period for the respective cookie file, depending on the type. 
  • until you withdraw your consent (decline data processing).

The withdrawal of consent procedure is described in Clause 5.7 «Right to withdraw consent.»

Transferring personal data to third parties

To accomplish this purpose, we connect to information resources of third-party services. We provide these services the opportunity to gather your personal data for analysis. In this case, the processing of your personal data is subject to the privacy policies of these third-party services.

Transferring personal data to third countries and international organisations

Your personal data will be processed in Luxemburg and other countries where the involved third-party services operate.

3.3. Data processing for internal Luxtoday purposes

In addition to the activity stated above, the platform operates outside of its information resources. The  platform processes your personal data in the course of its operation for the following purposes:

3.3.1. Accreditation of foreign media representatives for events organised or hosted by the Luxtoday

For the purpose of personal data processing

To provide media accreditation for events.

Personal data processed for this purpose

First name, last name, patronymic (middle name); gender; citizenship; identification document data; photograph; copies of passport pages; place of employment and job title; visa category and number; email; contact telephone numbers; purpose of visit to the country.

Legal grounds for processing your personal data

Your consent.

Period of storage of your personal data

For the period of accreditation and one year after the accreditation expires.

Transferring personal data to third parties

Your personal data will be transferred to third parties if the Luxtoday involves them in the event.

Transferring personal data to third countries and international organisations

Your personal data will be processed in Luxemburg and in the country where an event is held.

3.3.2. Inviting a guest speaker to an Luxtoday  news conference on EU territory

Purpose of personal data processing

To organise an Luxtoday event.

Personal data processed for this purpose

First name, last name, patronymic (middle name); photograph; place of employment and job title; email; contact telephone numbers; academic degree; profile; contact information for messenger sites and social media.

Legal grounds for processing your personal data

Your consent.

Period of storage of your personal data

Until the end of the event.

Transferring personal data to third parties

Your personal data will be transferred to third parties if the Luxtoday involves them in organising the news conference.

Transferring personal data to third countries and international organisations

Your personal data will be processed in Luxemburg and the country where the news conference is held.

3.3.3. Processing the data of representatives of the Luxtoday’s partners, contractors and clients in the EU

Purpose of personal data processing

Executing, performing and terminating a civil contract, approving a contract with a contractor.

Personal data processed for this purpose

First name, last name, patronymic (middle name); place of employment and job title; email; contact telephone number.

Legal grounds for processing your personal data

Actions towards executing a contract as well as performance of the contract (any type of contract).

Period of storage of your personal data

Until the execution of the contract as well as while it is valid, until termination/expiration.

Transferring personal data to third parties

No personal data is transferred to third parties.

Transferring personal data to third countries and international organisations

Personal data will only be processed in the Luxemburg.

3.3.4. Content production by a media outlet

Purpose of personal data processing

For media outlet operations.

Personal data processed for this purpose

First name, last name, patronymic (middle name); place of employment and job title; photograph; audio recording of an interview; video recording of an interview or speech; profile; email; contact telephone number; contact information for messenger services and social media.

Legal grounds for processing your personal data

Legitimate interest.

When gathering your data, we act based on our legitimate interests because no other grounds apply in this case. Our operation involves promptly responding to events in various areas of society and presenting them in the form of news content. When producing news content during the course of our operation as a media outlet, we may use personal data and these personal data will become publicly available unless it violates the rights and freedoms of an individual. We expect you to be aware of this.

Period of storage of your personal data

Indefinitely, as part of our journalistic activity as a media outlet.

Transferring personal data to third parties

No personal data is transferred to third parties.

Transferring personal data to third countries and international organisations

Your personal data will only be processed in Luxemburg.

3.3.5. Newsletters to representatives of European media outlets

Purpose of personal data processing

To distribute newsletters.

Personal data processed for this purpose

First name, last name, patronymic (middle name); place of employment; contact telephone number; email; country.

Legal grounds for processing your personal data

Your consent.

Period of storage of your personal data

Until you withdraw your consent.

The withdrawal of consent procedure is described in Clause 5.7 «Right to withdraw consent».

Transferring personal data to third parties

No personal data is transferred to third parties.

Transferring personal data to third countries and international organisations

Your personal data will only be processed in Luxemburg.

3.4. Automated individual decision-making and profiling

To accomplish the purposes for which we process your personal data, we do not engage in automated individual decision-making, including profiling.

4. Use of cookies

We use cookies to improve the quality of our services and your experience as a user. 

4.1 What is a cookie?

A cookie is a small text file stored by a website on the user’s terminal. The majority of websites use cookies to improve their functioning and optimize the browsing experience of their users.

4.2 Cookies used on the Luxtoday

  • Absolutely necessary cookies (Luxtoday internal cookies) are technical cookies allowing navigation on the platform and access to its functionalities and сontent. 
  • Functional cookies (Luxtoday internal cookies) make it possible to recognize you when you return to the Platform, to memorize the information relating to your preferences, and thus to improve your browsing quality: adapt the configuration of the Platform to your preferences. 
  • Audience measurement cookies (Google Analytics third-party cookies): these cookies are used to enable us to recognize and count the number of visitors on the Platform and to collect information on how it is used. (navigation route, most visited pages, etc.).

To find out more on Google’s privacy policy: Google Privacy Policy

4.3 Refusing and Deleting Cookies

  • Configuration of your browser settings​

If you wish to refuse cookies or delete cookies stored on your device, you can do so via the preferences of your internet browser. These navigation options relating to cookies are normally found in the «Options», «Tools» or «Preferences» menus of the browser that you use to access Luxtoday. However, according to the different existing browsers, different means can be used to disable cookies. To know more you can consult additional information from the referenced links below:

Please note that if you refuse to accept cookies from your internet browser on your device, some features and parts of the platform may not work properly.

  • Online deactivation of Google Analytics cookies

You may prevent your data from being used by Google Analytics by downloading and installing the add-on accessible on the following link: Disable Google Analytics

5. Your rights

5.1. Right to access your personal information

You have the right to obtain information from us about the processing of your personal data, the purpose of processing, categories, recipients or categories of recipients, including from third countries (outside the European Union or the European Economic Area) or international organisations, the period of storage, conditions of terminating the processing of your data and the source of your personal data.

If we process your personal data electronically, we will provide you with a copy of these data in a commonly-used format.

5.2. Right to correct your personal data

If your personal data is inaccurate, incomplete or outdated, you have the right to require that we correct it without delay on our part or, when appropriate, to correct it on your own, for example, in your personal account settings.

You will be notified once we have corrected your personal data.

5.3. Right to delete your personal data

You have the right to request that we delete your personal data without delay on our part or, when appropriate, delete it yourself, for example, in your personal account settings.

If we cannot delete your personal data, we will anonymise your personal data to make it impossible to identify the owner.

You will be notified once we have deleted or anonymised your personal data.

5.4. Right to restrict (block) processing

You have the right to request that we restrict (block) the processing of your personal data. You may, however exercise this right only in the following cases:

  1. You have disputed the accuracy of your personal data for a period that allowed us sufficient time to verify these data;
  2. Processing your personal data is against the law and you object to your personal data being deleted and request that we restrict their use;
  3. We no longer need your personal data for the purposes of processing but you need them to impose, pursue or protect your legal requirements;
  4. You object to the processing until it is verified that our legitimate grounds override your grounds.

If the processing of your personal data is restricted (blocked), we will suspend processing until the restriction is lifted but will continue to store your personal data.

You can lift the restriction (block) from the processing of your personal data at any time by sending us a request using the methods specified in Section 9 «Contacts».

5.5. Right to data portability

You have the right to obtain your personal data in a structured and machine-readable format as well as the right to have these data transferred to another controller if technically feasible.

You may exercise this right when your data is processed electronically on the basis of your consent or a signed agreement to which you are a party.

5.6. Right to object

You have the right to object to the processing of your personal data at any time based on a substantiated objection, when we process your data:

  • to perform tasks in the public interest or to exercise official authority conferred on us;
  • based on the legitimate interests that we or a third party pursue, except when pursuing these interests is necessary to protect your rights and freedoms.

We will not process your personal data if we cannot demonstrate convincing legal grounds for processing them.

You may also, at any time, object to our processing of your personal data for marketing purposes, including for profiling.

5.7. Right to withdraw consent

If your personal data are processed due to your consent, you have the right to withdraw it. We use a simple ‘withdrawal of consent’ procedure:

5.7.1. Withdrawal of consent to email newsletters.

You can withdraw your consent using any of the methods below:

  • click «unsubscribe» in any distributed email;
  • send us a withdrawal notice in a reply to an email newsletter;
  • turn off email newsletters in your personal account settings, where available.

5.7.2. Withdrawal of consent to personal data processing via your account on Luxtoday website.

You can withdraw your consent using any of the methods below:

  • delete your account in the settings of your personal account on Luxtoday website (you will find a link to delete your account in Settings);
  • send us a withdrawal notice using the methods specified in Section 9 «Contacts».

5.7.3. Withdrawal of consent to cookie processing (declining cookie processing).

You can withdraw consent (decline processing) following the steps in our in Section 9 «Contacts». Depending on type, cookies can be deleted automatically after you close the browser on your device. We will stop processing cookies that are not deleted automatically after you withdraw consent.

5.7.4. Withdrawal of consent to personal data processing for purposes unrelated to the use of our information resources.

You can withdraw your consent by sending us a notice using the methods specified in Section 9 «Contacts».

5.8. Right to file a complaint with a supervisory authority

You have the right to file a complaint with an authorised supervisory authority in your country if you have doubts about our methods for processing your data or protecting and enforcing your rights.

You can find contact information for your supervisory authority on the European Data Protection Board website

5.9. Request for additional information required to identify a data subject

If the data you provided are insufficient for observing your rights, we may request additional data from you to verify your identity. We do our best to request only essential information that is absolutely necessary. If you fail to provide additional information we will not be able to observe your rights. If you believe that we violate your rights by requesting additional information, you can file a complaint with a respective supervisory authority.

5.10. Terms of providing information on your rights

We provide information on observing your rights free of charge. If your request is clearly unsubstantiated or excessive (specifically, due to repetitiveness), we may refuse to respond or charge a fee for providing the requested information.

5.11. Exercising your rights

We provide several methods for exercising your rights:

  • You can use the online feedback form available on the website to send us a request regarding your personal data;
  • You can exercise your rights without assistance, when available, via your personal account;
  • You can address critical issues to our data protection officer: privacy@luxtoday.lu.

5.12. When we are restricted from observing your rights

According to Article 23 of the GDPR, we must restrict the scope of our obligations and your rights when it is required by the law of the European Union or an EU member state.

These restrictions may apply if your personal data are processed to safeguard:

  1. National security;
  2. Defence;
  3. Public security;
  4. The preliminary inspection, investigation, identity verification or the prosecution of criminal offences or the execution of criminal penalties, including the safeguarding against and the prevention of threats to public security;
  5. Other important objectives of general public interest of the European Union or of a member state in which you are located, in particular, an important economic or financial interest of the European Union or of a member state, including monetary, budgetary and taxation matters, public health and social security;
  6. The protection of judicial independence and judicial proceedings;
  7. The prevention, investigation, detection and prosecution of breaches of ethics for regulated professions;
  8. A monitoring, inspection or regulatory function connected to the exercise of official authority;
  9. The protection of the data subject or the rights and freedoms of others;
  10. The right to file civil law claims and enforce foreign court rulings.

There are also special conditions that must be met for your rights to be exercised, specifically:

Exemptions from the right to delete personal data:

  1. Observing the right to freedom of expression and freedom of information;
  2. Performing a statutory obligation that requires the processing of personal data under the law of the European Union or an EU member state, or accomplishing an objective of general public interest or for exercising official authority imposed on us by the law of the European Union or an EU member state;
  3. Protecting the public interest in the area of public health;
  4. Processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes;
  5. Initiating, conducting or defending a legal claim.

Exemptions from the right to restrict (block) processing:

  1. Introducing, meeting or defending legal requirements, upon your consent;
  2. Protecting the rights of another individual or a legal entity;
  3. Pursuing the important public interests of the European Union or an EU member state.

If we are not able to observe your rights upon your request, we will send you a substantiated refusal.

You have the right to file a complaint with a competent supervisory authority in your country if you have doubts with regard to our processing your data or protecting or observing your rights.

Your country’s supervisory authority’s contact information is available on the European Data Protection Board website.

6. Guarantees regarding personal data transfers to third countries

If we deal with a contractor whose country of operation is not on the list of countries ensuring an adequate level of personal data protection, we use standard contractual terms, as recommended by the European Commission. We have adopted security measures to protect your personal data according to the best security and privacy practices available. We use safety precautions to protect your information.

7. Data security

The personal data we collect and store constitute classified information. They are protected from loss, manipulation or unauthorised access, by virtue of technical tools and organisational procedures. We continuously improve our data protection systems.

We assess impacts on data protection in order to identify your risks during data processing. We minimise detected risks by employing technical and organisational security measures.

You are responsible for the safekeeping of the password we provide for your personal account on our website. You must maintain this password in confidence and never transfer it to anybody.

8. Policy amendments

We reserve the right to amend this Privacy Policy from time to time.

We will inform you of any changes to this Privacy Policy using the available means (via your contact email provided during registration or via our information resources during your next visit).

Please review every update to this Privacy Policy.

9. Contacts

To send us a message concerning the protection of personal data, please use the feedback form on the website.

You can address important questions about the protection of personal data directly to our data protection officer by e-mail: privacy@luxtoday.lu

Please note that this contact information can only be used for inquiries regarding personal data processing and protection. Unrelated inquiries will not be considered.

For inquiries unrelated to personal data protection, please use the contacts on the Luxtuday website: https://luxtoday.lu/contact/. Be sure to address your request to the appropriate department. If you send your request to the wrong department, your issue may remain unresolved because departments only respond to requests within their competence.

Last updated: 15.01.2021

Information sources to which data protection regulations apply

Source of information to which these data protection rules apply: https://luxtoday.lu

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