1. General information
Last update 10 mai 2022
1.1. Our commitment
Klima-Agence agrees to protect your privacy and ensure your personal information is protected. These rules of conduct concerning privacy protection explain the kind of personal data we collect and the way in which we use it, disclose it to third parties and protect it.
1.2. What does this document cover?
These rules of conduct concerning privacy protections apply to all personal data which you send as part of a procedure with a Klima-Agence employee or via one of our websites or applications and which we are capable of processing as part of the everyday management of our activities, namely data needed for fulfilment (i) of our contracts with clients, suppliers and backers, (ii) agreements signed with other players in the industry and (iii) our public interest assignment to raise awareness, advise, examine and train individuals in fields related to the rational and sustainable use of energy and sustainable mobility.
1.4. Who is responsible for your personal data?
Klima-Agence is responsible for complying with regulation applicable to processing of your personal data. As a result, Klima-Agence has appointed a data protection delegate. Below, you will find the relevant contact details:
Process manager |
Data protection delegate |
|
Name: Klima-Agence G.I.E.
|
Name: DPO (Data Protection Officer) |
1.4. Terms for changing these rules
We can modify these rules of conduct concerning privacy protection by publishing an updated version of this notice. We will give you reasonable notice of any significant change.
2. Klima-Agence principles on privacy protection
Klima-Agence takes privacy seriously. The following five principles form the basis of our approach to respecting your privacy:
- Klima-Agence will always use your personal data in a loyal and trustworthy manner.
- You have the right to be clearly informed of the way in which we are using your personal data. We will always be transparent with you concerning the data we are collecting and the way in which we are using it.
- If you have concerns regarding the way in which we use your personal data, we will help you to understand our processes.
- We will take all reasonable measures to protect your information against abuse and keep it safe.
- We respect all current regulation concerning the protection of personal data and cooperate with the Luxembourg data protection authority (CNPD).
3. Klima-Agence rules of conduct concerning privacy
3.1. Use of your consent
When collecting personal data which is not associated with a legal or contractual obligation, or a legitimate reason concerning our public interest assignment, Klima-Agence informs individuals that transmission of this data is optional and subsequent processing by Klima-Agence requires your consent. Where applicable, you will be offered a form or similar tool to facilitate the declaration of your agreement concerning the processing of optional personal data.
3.2. What personal data is affected and what are our collection sources?
Within these rules of conduct concerning privacy protection, your personal data refers to one or more pieces of information which could make it possible to identify you, either directly or indirectly. This generally includes information such as your name, your postal address, your email address, your telephone numbers, your bank details and your responses concerning transmission, by Klima-Agence, of an electronic newsletter. Based on the relationship you have with Klima-Agence, other personal data may be added. Please consult the table below to familiarise yourself with the other personal data we collect:
|
Relationship |
Other personal data collected |
|
External climate consultants (Climate Pact) or applicants/holders of the “Klima-Agence certified" certificate |
Curriculum vitae, academic career, professional qualifications and experience, consulting reports issued, current employer |
|
Beneficiary of basic advice or advice as part of the fuel poor households assistance project |
Characteristics of the housing contact details: name, address, telephone, email address |
|
Accountant of Klima-Agence |
LuxTrust electronic signatures |
|
Users of the grant simulator |
Email address after consent for 36 months, IP address for 1 week |
All the personal data processed is limited to the personal data which you have given us, which is publicly accessible on the website of your organisation or an organisation which is associated with yours (for example, federation, trade union, etc.) or which reaches us via an intermediary that you have authorised to send your personal data (for example, municipal authorities, corporate offices, etc). We do not collect other information from other sources.
3.3. How do we use your personal data ?
We use your personal data as part of our organisation’s comprehensive management of activities, namely:
- Fulfilling the obligations established by contracts and agreements signed with you or with our partners (municipal authorities, corporate offices, etc.);
- Managing orders for documents and services (consulting, raising awareness, training, certification, etc.);
- Establish statistics regarding the use of our websites and applications;
- Executing tasks associated with the public interest assignment entrusted to Klima-Agence;
- Managing invoices, payments and calls for contributions;
- Communicating with you concerning our activities and news in fields associated with the rational and sustainable use of energy and sustainable mobility.
- Send you the results of your simulations in the grant simulator after you have given your consent. You may receive a link to reconnect to your unfinished simulation and a PDF containing the results of your simulations.
When we collect personal data for these purposes alone, we do not keep them for longer than is necessary for satisfying this purpose, unless we must keep them for legitimate legal reasons. Different retention times have been defined depending on the nature of the personal data, however, personal data that is no longer in use will be erased within 10 years of its collection.
In order to protect this data against accidental or malicious destruction, when we remove it from our offices, it may be that we do not immediately remove the remaining copies on our servers or on our backup systems.
3.4. With whom do we share your personal data?
As a general rule, we do not share your personal data outside of Klima-Agence. However, some IT providers have technical access to your personal data as part of their maintenance and development tasks on our various systems. Based on the backup location of the database or the electronic document containing your personal data, various providers are in charge and other suitable security measures have been put in place. Your personal data may be found on hard copy documents on our premises or on electronic documents either on IT servers on our premises or on the IT servers of one of our IT suppliers, or in a data centre hosting the databases associated with our websites or mobile applications.
In case of postal shipping, your name and postal address data are sent to a printer responsible for printing and distributing the correspondence in question.
According to current legislation, our subcontractors, who are detailed above, are required to respect the same rules of conduct concerning confidentiality and data protection as those that apply to Klima-Agence.
We can also share your personal data with organisations if we believe that disclosure of information is necessary for legal reasons, as part of proceedings.
3.5. Do we transfer your personal data to other countries?
As a general rule, we do not transfer any of your personal data outside of Luxembourg and we use subcontractors who commit to keeping your data in Luxembourg. In case of a change in the relevant policy, this transfer will be made according to law concerning privacy protection and you will be informed of this.
There are two exceptions to the aforementioned rule where we collaborate with subcontractors who are either located outside of the European Union, or who have indicated that they are transferring the personal data outside of the European Union or to international organisations. More specifically, this is “The Rocket Science Group LLC” which is located in the United States and makes their online MailChimp platform available to us, allowing us to regularly send newsletters to your email address. The other exception is the WeTransfer service offered by the company “WeTransfer B.V.” which is headquartered in the Netherlands and has indicated that it transfers personal data outside of the European Union or to international organisations. We use WeTransfer to transfer documents to our providers that are too large to email. These documents may potentially contain personal data. Data processing agreements have been signed with the two aforementioned companies in order to ensure your personal data protection rights continue to be respected.
3.6. How do we protect your personal data?
We take all reasonable precautions to store your personal data securely and we require any subcontractor handling or processing your personal data to act accordingly.
If Klima-Agence collaborates with other companies, these subcontractors will only be selected after a selection process which also covers technical and organisational skills relating to data protection. A service contract stipulating processing of your personal data will only be executed if it complies with the security requirements identified, including European and national regulatory requirements.
Access to your personal data is restricted in order to avoid all unauthorised access, modifications or misuse, and it is only authorised for employees who need access as part of their work.
3.7. Specific use of your personal data collected via our websites (www.klima-agence.lu, www.pacteclimat.lu, www.stroumbeweegt.lu, etc.)
3.7.1. Cookies – What are they?
Cookies are small text files which can be stored on the computer or mobile device of a visitor to a website by their web browser.
Cookies used by Klima-Agence are performance and statistical cookies that collect information about how visitors use our website. They are used to analyse the use of our website anonymously or under a pseudonym and to offer the user advanced features. They do not keep track of any personal information about a user and identifiable data will never be stored.
Use of the website is not possible without cookies. When you log on to our site you will be asked to confirm your cookie preferences. Generally, you can prevent the storage of cookies on your hard disk by selecting the corresponding option in your browser's settings. You can also configure your browser to request authorisation before storing cookies. Finally, you can remove pre-set cookies at any time. Please refer to your browser’s instructions to obtain instructions concerning the method for implementing this measure.
By using our website, you agree to receive this type of cookies on your device.
3.7.2. Cookie management
Klima-Agence uses client cookies, small text files which make it possible to analyse information relating to the user's navigation (frequency of visits, duration of visits, pages consulted, language preferences, etc.). They are deposited by Klima-Agence in a directory provided for this purpose on the user's computer. They contain, in particular, the name of the server that wrote it, an identifier in the form of a unique number and an expiry date. The unique identifier allows Klima-Agence to recognize the user's computer at each visit. Session cookies are deleted from the user's computer when the session is closed. However, persistent cookies remain on the user's computer for 1 month after the end of the session.
The user can decide for himself whether or not the Klima-Agence web server is authorised to store cookies on his computer. At any time, he/she can adjust the options of his/her browser so that cookies are not accepted and memorized. Furthermore, the user may, at any time, delete, via the browser, cookies that have already been stored.
The use of certain functions of the klima-agence.lu site may be limited or deactivated if the user refuses the site's cookies. It is therefore recommended that the user adjust his browser so that cookies from the klima-agence.lu site are accepted.
3.7.3. Use of Adobe Analytics
Our site uses Adobe Analytics. This service makes it possible to analyse access to Klima-Agence websites and allows us to improve our online presence. The information collected using cookies (IP address, access time, access duration) is sent to the Adobe servers in the United States and stored there. The assessment of activities on our website is sent to us in the form of reports. Adobe can send the information collected to third parties, if these third parties process this data on behalf of Adobe or if the law requires it.
However, our Adobe Analytics tracking codes are configured in such a way that the data is managed anonymously, meaning that the IP addresses processed are uniquely shortened in order to exclude any direct personal connection with you. You can also prevent storage of cookies by Adobe Analytics by configuring your browser accordingly. In this case, however, you may not be able to use all the features on our website.
By using our website, you authorise the processing of data collected by Adobe concerning you.
3.7.4. Use of data concerning users’ behaviour for information and advertising purposes
Our system for analysing the use of our website is also capable of establishing a temporary and anonymous user profile, allowing us to adapt the information and adverts displayed to the user concerned.
3.8 The aid simulator
The aid simulator uses cookies to follow the user's path through the connection. The connection is anonymous, no personal data is given or saved.
Functional cookies (for the proper functioning of the simulator) are used to memorise the language and the choices made by the user and have a lifetime of one week.
Pseudonymised data is saved without a fixed lifetime. Personal data (email address given with consent) are saved on the Klima-Agence server for a period of 36 months.
3.9. Presence on social networks
MODERATION POLICY
- Any user who joins the Klima-Agence community on social networks agrees to refrain from any form of discrimination related to race, colour, religion, sex, sexual orientation, age, national origin, disability, marital status or professional status.
- Abusive, racist, sexist or offensive language has no place on social networks. They will be deleted and reported.
- The main objective of Klima-Agence's social network accounts is to relay information and content published in connection with the themes of sustainable housing and mobility.
- Klima-Agence's social network accounts are not intended to deal with requests, questions and comments containing personal data such as surnames, first names, national identification numbers, dates of birth, telephone numbers, email addresses, or attachments or scans of documents containing personal data.
- For such requests, questions or comments, users of the Klima-Agency community should use the contact form available on klima-agence.lu.
- In this regard, requests, questions or comments containing personal data (the identifier of the person's account on this social network not being generally taken into account) made on the accounts of Klima-Agence on the social networks will not be processed and will be, as far as possible, deleted.
- Klima-Agence's Facebook, Youtube and LinkedIn applications are in principle monitored from Monday to Friday, between 08.00 and 17.00 hours. Outside of these hours, as well as during weekends and public holidays, the administration of the pages is not guaranteed on a continuous basis.
LANGUAGES
On social networks, Klima-Agence communicates in French, German, English and Luxembourgish.
4. What are your rights and how do you exercise them?
If you have questions, comments or concerns regarding the way we process your personal data, you can contact the controller or the data protection delegate directly at the contact details found above.
You are entitled to:
- ask us for a copy of the personal data we hold concerning you,
- ask us to correct, update or remove your personal data in our files, and
- inform us of any misuse of your personal data.
If you no longer wish to receive newsletters from us, you can inform us at any time by contacting us or using the link you will find in each of our newsletters.
If you think your personal data has not been processed legally, you are entitled to contact the CNPD (www.cnpd.lu or databreach@cnpd.lu) and to file a complaint with the CNPD. However, we encourage you to contact us concerning the problem beforehand, in order to clarify the situation.