Privacy Policy

The purpose of this specific notice is to explain the processing of personal data of "participants" who register online for an event organised or co-organised by Luxinnovation and/or of "members" when they join an online community. The complete privacy notice can be consulted via the following link: https://luxinnovation.lu/privacy  

Contents: 
a) Who is the data controller? 
b) What personal data is collected? 
c) For what purposes does Luxinnovation process your data and what is the legal basis for such processing? 
d) Who has access to your personal data? 
        i. Luxinnovation employees 
        ii. Luxinnovation partners and shareholders 
        iii. Service providers 
e)  How long is your data kept? 
f) How is your data protected? 
g) What are your rights and how can you exercise them? 

a. Who is the Controller? 
Luxinnovation GIE (hereafter "Luxinnovation") is registered under number C16 with the Luxembourg Trade Register. Its head office is located at N°5, Avenue des Hauts-Fourneaux L-4362 ESCH-sur-ALZETTE. 

 You can submit your questions and requests by sending an email to: gdpr@luxinnovation.lu 

Depending on the event, Luxinnovation is either the data controller (which determines the purposes and means of the processing of your data) or the joint data controller (which determines the purposes and means of the processing of your data in collaboration with its shareholders and partners) when the event is co-organised. The form provided for you to register or pre-register provides information on the name(s) and position(s) of the data controller or joint data controllers.  

b.  What personal data is collected? 
“Personal data" means any information relating to an identified or identifiable natural person (hereinafter referred to as "data subject”). Luxinnovation has integrated the "Inwink" online event registration platform into its own platform to make it easier for you to apply to take part events and/or join online communities, and to ensure the greatest possible convenience for you. The registration forms used are created by Luxinnovation and are its property. They include mandatory fields: 
 Identification data: surname(s), forename(s); positions in the company or public institution, legal name and country of the company or public institution; 
 Contact data: email address (private or professional, at the discretion of the data subject). 

This data is collected by Luxinnovation, which stores it in its database.

In the specific case of online communities, this data will be visible only to group members, with the exception of email addresses, which remain strictly private. The data subject can also fill in other optional fields if he/she wishes: the company website and an avatar (a photo or other image chosen by the data subject). During the event itself, photographs, videos and/or sound recordings may be made. This information appears on the registration form you fill out to take part in Luxinnovation events. Professionals duly commissioned by Luxinnovation are instructed to adopt overall and group views, with the exception of speakers, guests and Luxinnovation staff. 

You have the right to refuse this processing of your personal data: Luxinnovation invites you to get in touch with our staff when you receive your personal badge. If the event is held online, you will be asked to deactivate your camera and/or microphone. 

3. For what purposes does Luxinnovation process your data and what is the legal basis for such processing?  
When you take part in one or more events organised by Luxinnovation, alone or in partnership with other Luxembourg organisations, or are a member of one or more online communities, your data is processed for the following purposes, based on Luxinnovation's missions of general interest, as detailed below (updated articles of association of 14 May 2012, article 2):

Luxinnovation also processes your data for other purposes not provided for in Luxinnovation's articles of association:  
d) Who has access to your personal data?
In the case of online communities, Luxinnovation does not share any personal data. Data is only accessible to group members. 

           i. Luxinnovation employees  
 Your personal data is only processed by duly authorised Luxinnovation employees, within the limits of their respective duties. These employees are regularly made aware of GDPR issues. A GDPR Officer is appointed to provide them with all his expertise in the event of questions. 

           ii. Event co-organisers
In the case of events co-organised with its Luxembourg institutional partners (national federations, ministries, administrations, embassies, professional chambers), Luxinnovation may transfer your data to them for information and/or statistical purposes. 
This sharing of personal data takes place via a write-protected file (which cannot be copied, modified or extracted) in a container, the access rights to which are restricted to authorised persons only. 
The co-organisers (recipients of the data transmitted by Luxinnovation) may, on their own responsibility, disclose the personal data to their agents and/or authorised representatives (the "sub-recipients"), who will process the personal data for the sole purpose of assisting the recipients in providing their services to Luxinnovation and/or assisting the recipients in fulfilling their own legal obligations. 

          iii. Service providers 
In order to provide its services, Luxinnovation uses several external suppliers, some of whom may have access to your personal data. In this context, to ensure the protection of your personal data: 
a.  our suppliers are selected according to strict criteria: they offer sufficient guarantees to implement appropriate technical and organisational measures. 
b.  contracts concluded with each service provider include either a confidentiality clause or a data protection agreement.  

e) How long is your data kept? 

Your personal data collected when you register online with Inwink will be deleted within 24 months of the date of the event for which you registered. 
Concerning the protected document, shared by Luxinnovation with its potential co-organisers: personal data is deleted within 10 days of being made available. 

The Luxinnovation database: the personal data collected during your event registration is stored in Luxinnovation's database. It is deleted within 36 months of the date of last contact, unless you exercise your right to erasure (see below: What are your rights and how can you exercise them? 

Within online communities: members' profiles are kept for a period of 24 months from the validity of their membership. A notification is sent to them by our systems to invite them to reconfirm their membership and explicit consent. If the member does not wish to extend his/her membership: his/her profile is deleted but exchanges with other forum participants are preserved; the author of these exchanges and his/her profile are then anonymized (his/her contact details and photo/avatar no longer appear). 

Luxinnovation may, at its sole discretion, unilaterally decide to disband online communities. All data collected (member profiles) and all forum exchanges will then be permanently deleted. 

The consent you give Luxinnovation to process your personal data is retained for a period of 12 months from the date on which you authorise the processing concerned. After 12 months, you will be asked by our systems to renew your consent. 

If you wish to exercise your rights: requesting parties’ personal data will be deleted within five years of the date the request was sent, regardless of the purpose of the request or Luxinnovation's response.  

f) How is your personal data protected? 
In accordance with the requirements of the GDPR, Luxinnovation has technologies at its disposal that guarantee the security of its data, including your personal data. Furthermore, we have a team of experts who are committed on a daily basis to developing and implementing the technical and organisational security measures required to ensure the highest standards in this field. Security audits are carried out in order to regularly improve systems for detecting risks of piracy, unauthorised disclosure, total or partial accidental loss, and/or unlawful modification of your data. 

g. What are your rights and how can you exercise them?

As a data subject, you have various rights. Below is a brief description of these rights and how you can exercise them, via the e-mail address GDPR@luxinnovation.lu. 
Right to information: you can send us any questions regarding the recording and processing of your data. 
Right of access: you may, at any time, by way of a simple written request to Luxinnovation, obtain confirmation as to whether or not personal data concerning you is being processed and, if that is the case, obtain access to such data and a free copy of the same. 
Right of rectification: you may, at any time, by way of a simple written request to Luxinnovation, insist on the rectification of any inaccurate personal data concerning you. You can also make a request for incomplete data to be rendered complete in the same way. 
Right to erasure: you may, at any time, by way of a simple written request to Luxinnovation, have your data deleted, provided that one of the following reasons applies: 
  • the data is no longer necessary for the purposes for which it was collected and processed; 
  •  you have withdrawn your consent on which the processing was based and there is no other legal basis for this; 
  •  you object to the processing and there is no compelling legitimate reason for such processing; 
  •  the data has been processed unlawfully; 
  •  data must be deleted to comply with a legal obligation. 
Right to restriction of processing: you may request, by writing to Luxinnovation, that processing be restricted for one of the following reasons: 
  • you dispute the accuracy of the personal data (processing will be restricted to the time necessary to verify the accuracy of the data); 
  • in the event of unlawful processing, you object to the erasure of your data and request that its use be restricted; 
  • we no longer need your data for processing purposes, but it is still necessary to establish, exercise or defend legal rights; 
  • you have objected to the processing (the processing will be restricted for the period of time necessary to verify the existence of legitimate grounds pursued by Luxinnovation that would prevail over yours). 
Where processing restrictions are granted, personal data may – with the exception of storage – only be processed with the consent of the data subject for the establishment, exercise or defence of legal rights, or for the protection of the rights of another nat

Right to object: You have the right, on grounds relating to your particular situation, to object at any time to the processing of your data based on the execution of a public mandate or this being necessary for the legitimate interests pursued by us, simply by sending us a request in writing. 
We will no longer process such personal data unless it can be shown that there are compelling legitimate grounds for processing which override your interests and rights and freedoms, or for the establishment, exercise or defence of legal claims. 
When your personal data is processed for marketing purposes, you have the right to object to this processing at any time. 

Right to data portability: You have the right, by sending us a written request, to receive your personal data provided to us by you in a structured, commonly used and machine-readable format, and to transmit this data to another controller without Luxinnovation's hindrance, when: 
  • processing is based on your consent or on a contract; 
  • and the processing is carried out using automated processes. 
Right to withdraw your consent: Where processing is based on your consent, you have the right to withdraw this at any time by sending us a written request. The withdrawal of your consent will not affect the lawfulness of the processing based on the consent given prior to such withdrawal. 

Right to lodge a complaint: We make every effort to ensure that our legal obligations concerning data protection are respected and respond to any complaint addressed to us in this respect as quickly as possible. 

We draw your attention to the fact that Luxinnovation reserves the right to verify your identity before granting your request to exercise the rights provided for under the GDPR. As a reminder, the exercise of your rights does not outweigh the prior validity of the processing applied to your personal data. 
Should processing your request require Luxinnovation to mobilise human and technical resources over a given period of time, we reserve the right to invoice you for our services in this regard. 
All requests will be kept for five years from the date your request is sent. 
 For any questions regarding the processing of your personal data by Luxinnovation, and for any questions relating to the exercise of your rights, please contact Luxinnovation's GDPR Officer: GDPR@luxinnovation.lu.  

If you are not satisfied with the response you receive, you have the option of filing a complaint with the Luxembourg supervisory authority. Commission Nationale pour la Protection des Données (National Data Protection Commission) ("CNPD"). 15, Boulevard du Jazz L-4370 Belvaux Grand Duchy of Luxembourg You also have the option of contacting the supervisory authority in your own country. You can find contact details for all the supervisory authorities by clicking on the following link: https://www.edpb.europa.eu/about-edpb/about-edpb/members_en
Last modification: October 2024 

3.4. If you participate in events that Luxinnovation organises, alone or in partnership with other organisations, Your Data are processed for the following purposes:
3.5. If you are visiting our website, Your Data are processed for the following purposes: 
  • to create and manage the users’ account (i.e. to perform any pre-contractual measures as well as the contract entered into by the users); 
  • to enable the Data Subjects to use the functionalities of the platforms and websites (i.e. to perform any pre-contractual measures as well as the contract entered into by the users); 
  • to manage the relationship between Luxinnovation and the user (i.e. to perform any pre-contractual measures as well as the contract entered into by the users); 
  • to enable the User to access other platforms, tools and services provided by Luxinnovation (i.e. to perform any pre-contractual measures as well as the contract entered into by the users); 
  • for prospective purposes (i.e. for the legitimate interests of Luxinnovation in developing its activities). 
 3.6. In all cases and depending on how you are / come into contact with Luxinnovation, Luxinnovation may process Your Data for the following purposes, on the basis of its legitimate interest in protecting its rights and physical and logical assets: 
  •  identify you and give you access to our buildings/parking if you visit our premises; 
  • organize meetings and video conferences if you take part to such meetings; 
  • keep the IT infrastructure safe by filtering the Internet traffic (if you connect to our network); 
  • to verify compliance with ethics and embargo policies and possible legal or regulatory requirements in order to avoid and manage ethics incidents; 
  • for litigation or defence of claims. 
The Data Subjects may, at their discretion, refuse to communicate the Personal Data to Luxinnovation. In this event however, some Luxinnovation services may not be available (for example, the Data Subjects will not be able to create a user account on Luxinnovation websites).
4. Why does Luxinnovation share Your Data? 

Your Data may also be processed by the Luxinnovation’s data recipients (the “Recipients”) which, in the context of the above mentioned purposes, refer to any third party supporting the activities of Luxinnovation. 
For the aforementioned purposes, Luxinnovation may transfer Your Data to: 
  • its institutional partners (Luxembourgish ministries, administrations or/and federations, Professional Chambers, University, Public research organisations, Embassies, Trade organisations) or non-institutional partners (Luxembourgish Private research organisations, service providers for the joint organisation of events for example), 
  • its service providers for the sending of newsletters and other publications; 
  • its subcontractors that process data on its behalf. 
For the purposes of its international activities (preparation of international trade and invest missions, response to requests from companies located outside the European Economic Area, etc.), Luxinnovation may transfer Your Data to an international organisation or a country located inside and outside the European Economic Area: 
  • subject to an adequacy decision made by the European Commission; 
  • not subject to an adequacy decision made by the European Commission, to which such transfers are governed by way of appropriate guarantees (such as the European Commission’s standard contractual clauses) in order to guarantee an adequate level of protection for the transferred data in all circumstances; 
  • in the absence of an adequacy decision or appropriate guarantees, on the basis of your explicit consent. 
The Recipients may, under their own responsibility, disclose the Personal Data to their agents and/or delegates (the “Sub-Recipients”), which shall process the Personal Data for the sole purposes of assisting the Recipients in providing their services to Luxinnovation and/or assisting the Recipients in fulfilling their own legal obligations.

5. How long will Your Data be kept? 

The duration of the storage of your data will be determined by: 
  • the purposes detailed above; 
  • any legal or regulatory obligations to keep data; 
  • the applicable legal limitation period. 
The main applicable deadlines are as follows: 
  • the data of unsuccessful candidates applying for a position at Luxinnovation is eliminated after two years. The personal data of the selected candidate is transferred to his/her "Luxinnovation Employee" file and enriched according to the requirements of the Employer-Employee relationship;
  • when Luxinnovation learns (social networks, a definitive out of office, oral information, non-delivery of Luxinnovation emails…) that an employee or representative of a company with which it is in contact for one of the above purposes has left that company, the person’s contact record is deactivated;
  • when a person opts out of a processing operation based on his or her consent, that person's name is removed from the marketing lists with which he or she is associated.  
6. What are your rights and how can you exercise them? 

As a data subject, you have various rights. Below is a brief description of these rights and how you can exercise them. 
  •  Right to information : You can send us any questions regarding the recording and processing of Your Data. 
  • Right of access : You may, at any time, and by written request to us, obtain confirmation that Personal Data concerning you is processed or not and, where applicable, obtain access to such data and a free copy thereof. 
  • Right to rectification : You may, at any time, and via a written request addressed to us, obtain the rectification of any inaccurate personal data concerning you. You can also request that incomplete data be completed in the same way. 
  • Right to erasure : You may, at any time, and by written request to us, obtain the deletion of Your Data, provided that one of the following reasons applies: 
o the data is no longer necessary for the purposes for which it was collected and processed; 
o you have withdrawn your consent on which the processing was based and there is no other legal basis for it; 
o you object to the processing and there is no compelling legitimate reason for it; 
o the data has been unlawfully processed; 
o the data must be deleted in order to comply with a legal obligation. 
  • Right to limitation of processing: You may request, by sending a written request to us, that the processing be limited for one of the following reasons: 
o you dispute the accuracy of the Personal Data (processing will be limited for the period necessary to verify the accuracy of the data); 
o in the event of unlawful processing, you object to the deletion of Your Data and request that its use be limited; 
o we no longer need Your Data for processing purposes, but it is still necessary for you to establish, exercise or defend legal claims; 
o you have objected to the processing (the processing will be limited for the period necessary to verify the existence of legitimate grounds pursued by Luxinnovation that would prevail over yours). 
Where processing restrictions are granted, personal data may, with the exception of storage, be processed only with the consent of the data subject, or for the establishment, exercise or defence of legal rights, or for the protection of the rights of another natural or legal person, or for important reasons relating to the public interest. 

  • Right of opposition : You have the right to object, at any time and by sending a written request to us, for reasons relating to your particular situation, to the processing of Your Data based on the performance of a public mandate or necessary for the legitimate interests pursued by us. We will no longer process such personal data unless it is demonstrated that there are legitimate and compelling reasons for processing that prevail over your interests and rights and freedoms, or for the establishment, exercise or defence of legal rights. When your personal data is processed for the purpose of prospection, you have the right to object at any time to this processing. 
  • Right to portability : You have the right, by sending a written request to us, to receive the personal data concerning you that you have provided to us in a structured, commonly used and machine-readable format, and to transmit such data to another controller without Luxinnovation hindering it, when: o the processing is based on your consent or a contract; and o the processing is carried out using automated processes. 
  • Right to withdraw consent : Where the processing is based on your consent, you have the right to withdraw it at any time by sending a written request to us. The withdrawal of your consent will not affect the lawfulness of the processing operation based on the consent given before it was withdrawn. 
  • Right to lodge a complaint: We make every effort to ensure that our legal obligations regarding data protection are respected and to respond as quickly as possible to any complaint addressed to us in this regard.    
For any questions regarding the processing of your personal data carried out by Luxinnovation, and for any queries regarding the exercise of your rights, please contact the Luxinnovation DPO : dpo@luxinnovation.lu. 

In the event that you are not satisfied with the response received, you have the option of filing a complaint with the Luxembourg supervisory authority: 

Commission Nationale pour la Protection des Données (the “CNPD”)
15, Boulevard du Jazz
L-4370 Belvaux 
Grand-Duchy of Luxembourg 

You also have the option of contacting the supervisory authority in your country. You will find the contact details of all the supervisory authorities here: https://edpb.europa.eu/about-edpb/board/members_en. 

 Last modification: April 2023 

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