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Data Protection Policy​

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This data protection policy (the “Data Protection Policy”) of the Luxembourg Alternative Administrators  Association (“L3A”) sets out the rules and procedures as to the collection, processing and transmission of personal data (i.e. data by which you may be directly or indirectly identified, hereafter the Personal Data) in accordance with the Data Protection Legislation when accessing and browsing the website www.l3a.lu (the Website).

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Data Protection Legislation means the General Data Protection Regulation (EU) 2017/69 of the European Parliament and of the Council of 27 April 2016 (“GDPR”), as well as any other applicable laws, regulations and sector recommendations containing rules for the protection of individuals with regard to the processing of Personal Data.

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  1. Who is the data controller and who to contact?
     

Personal Data collected on the Website are processed by L3A. 

L3A is the association for the Luxembourg alternative administrators industry. It has its registered office at 63-65 rue de Merl,

L-2146 Luxembourg, and is incorporated as non-for-profit association under the Luxembourg Trade and Companies Register.

Should you have any requests concerning your Personal Data, you can contact L3A at the address indicated above or at contact@l3a.lu

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  1. For which purposes does L3A process personal data and on which legal basis?

    2.1 For purposes that are in L3A’s or a third party’s legitimate interest

    The purposes of the processing by L3A are notably to:

  • promote the industry in Luxembourg, to give a voice to the industry vis-à-vis public authorities, to provide for networking opportunities to professionals working in the industry;

  • foster community building within the alternative administrators industry;

  • manage the relationship with L3A members, in particular for membership administration, networking and sharing the information with other members or official or public bodies;

  • improve the performance and usability of the Website;

  • send updates and announcements about L3A services;

  • establish statistics and the conduct of Website trends, performance and commercial analysis;

  • assure the safety and continuity of L3A’s IT services and systems;

  • detect fraud;

  • establish, exercise and defense of legal claims; and

  • in connection with any business reorganisation, transfer, disposal, merger or acquisition on the level of L3A.

       A third party includes : 

  • financial or fraud investigation authorities

  • relevant regulatory authorities

  • external auditors or inspectors

  • organizations we’re legally obliged to share personal information with

  • suppliers and service providers


      2.2. With your consent
 

Insofar as you have given L3A your consent for the processing of your Personal Data, such consent will serve as a legal basis for the referred processing.

This includes the consent you may have given in relation to the use of cookies or the possibility to be contacted in relation of marketing purposes relating to our events and information about our activities, as well as to receive L3A’s newsletter.

You can withdraw your consent at any moment by contacting L3A at the address indicated in clause 1.

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    3. What personal data is processed?
 

L3A receives and collects the Personal Data directly from you or through the use of automated technology when you use and interact with the Website.

In particular, the Personal Data L3A processes about you may include:

  • personal data that you provide by filling in forms on the Website or using the contact details (this may include the first name, last name, company or organization for which an individual works, function or title within a company or organization, office address, membership status, email address, telephone number). Not all of these fields are complete for every contact and which of the above data fields L3A holds on each of its contacts depends on what information was available at the time of collection.

  • data technically transmitted when you access or browse the Website, such as IP address and data notably obtained through the use of cookies (including date and time of access, language preferences, operating system used, number of visits, pages of the Website you have visited, etc

No personal data shall be collected that are, by their nature, particularly sensitive in relation to fundamental rights and freedoms and merit specific protection.​

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    4. Cookies
 

A “cookie” is a small piece of text that a website places in the cookie file of your browser and that allows the website to remember who you are.

Like many other website, L3A uses cookies to provide you with a safe, effective and user friendly Website. L3A also uses cookies to compile certain information to determine visitor’s preferences and trends in web browsing activity.

You have the choice of deciding whether to accept cookies or not by setting your browser to block some or all cookies. However, please be aware that if you do not accept cookies, you may not be able to enjoy a comprehensive experience of the Website features. Strictly technical cookies, necessary to the functioning of the Website cannot be refused.

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    5. Who receives your personal Data?
 

The following recipients may receive your Personal Data:

  • Service providers, including but not limited to IT or website services suppliers, including VitalBriefing which is in charge of assuring the newsletter communications;  financial, tax or legal advisors, that process your Personal Data on L3A’s instructions;

  • The operator of the general homepage by which the Website is accessible;

  • Government, judicial and supervisory authorities.

 

    6. Where is your personal data transferred to?
 

The Personal Data are not transferred outside of the European Economic Area (the EEA).

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    7. How long does L3A retain your personal data?
 

The retention periods for your Personal Data are based on L3A’s business needs and legal requirements.

L3A may notably retain:

  • Personal Data you have submitted to L3A through a specific request until we have responded to your request or until the end of the exchange relating thereto, plus ten (10) years as of the end of such communication; and

  • cookies up to six (6) months after your last use of the Website.

L3A may also retain your Personal Data other than those related to cookies for up to two (2) years for statistics, business analysis and marketing purposes.

 

    8. ​Do you have the obligation to provide the Personal Data?
 

In the context of L3A’s business and the functioning of the Website, you only have to provide the Personal Data that is necessary for L3A to reply to your requests or necessary for the Website to run properly.

However, please be aware that without certain types of Personal Data (notably Personal Data relating to cookies technically required to be able to browse the Website), L3A will not be able to duly reply to your requests or some parts of the Website may become inaccessible.

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    9. To what extent does L3A use automated decisions making or profiling?
 

In general, L3A does not use automated individual decision-making or profiling in the course of the relationship with you. Should L3A rely on such processing, L3A would inform you separately, insofar L3A is legally required to do so.

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​    10. What are the rights of the users?

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    10.1 Right to information, rectification, erasure and restriction of processing

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You may request to obtain at no costs, within reasonable intervals, and in a timely manner, the communication of your Personal Data being processed, as well as all information on the origin of those Personal Data.

You also have the right to rectify your Personal Data that is inaccurate.

In cases where the accuracy of the Personal Data is contested, the processing is unlawful, or where you have objected to the processing of your Personal Data, you may ask for the restriction of the processing of such Personal Data. This means that Personal Data will, with the exception of storage, only be processed with or for the establishment, exercise or defense of legal claims, for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or of an EU Member State. In case a processing is restricted, you will be informed before the restriction of processing is lifted.

You may request the deletion of Personal Data, without undue delay when the use or other processing of such Personal Data is no longer necessary for the purposes described above, and notably when consent relating to a specific processing has been withdrawn or where the processing is not or no longer lawful for other reasons.

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     10.2 Right to object

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You may object to processing of your Personal Data which is based on the legitimate interests pursued by L3A or by a third party. In such a case L3A will no longer process your Personal Data unless L3A has compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.

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     10.3 Right to withdraw consent

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You have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal. The withdrawal only affects future processing.

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     10.4 Right to data portability

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Where the processing of your Personal Data is based on consent or the execution of a contract with you, you also have the right to data portability for information you provided to L3A– this means that you can obtain a copy of your Personal Data in a commonly use electronic format so that you can manage and transmit it to another controller.

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     10.5 Right to lodge a complaint

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In the event that you wish to make a complaint about how L3A processes your Personal Data, and/or if you want more details on the processing of your Personal Data and/or if you have any specific queries or concerns regarding the processing of your Personal Data, please contact L3A in the first instance using the contact details provided in clause 1 and L3A will endeavor to deal with your request as soon as possible.

This is without prejudice to your right to file a complaint with the Luxembourg data protection authority, the Commission nationale pour la protection des données, or any other competent data protection authority (e.g. that of your country of residence), in the event you have concerns on the processing of your Personal Data.

 

    11. Links to third party websites
 

The Website might contain link to third party websites.

This Privacy Policy solely concerns the Website, and L3A’s processing of Personal Data.

Please check the privacy policy of these third parties’ websites to learn about how they process your Personal Data under their own responsibility.

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    12. Amendments of this privacy notice
 

L3A may amend this Privacy Notice from time to time to ensure that you are fully informed about all processing activities and L3A’s compliance with applicable Data Protection Legislation. You will be notified of changes to the Privacy Notice by appropriate means.

 

 

Updated on 10/10/2024

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