Privacy policy

PERSONAL DATA SECURITY AND CONFIDENTIALITY POLICY

Introductory remarks

AGORA S .àr.l. et Cie (hereinafter, for convenience “AGORA”), a company incorporated under Luxembourg law, with head office located at 3 Avenue du Rock ‘n’ Roll – L 4361 Esch-sur-Alzette, is responsible for the collection and processing of your personal data, understood here as any information relating to an identified or identifiable natural person..

AGORA intends to manage this data in strict compliance with your rights and Regulation (EU) 2016/679 of 27 April 2016 (hereinafter, for convenience, the “GDPR”).

AGORA is therefore committed to respecting your privacy and protecting your personal information, under the conditions and according to the terms set by the legislation in force.

AGORA invites you to understand its Personal Data Security and Confidentiality Policy through TEN (10) questions. This security and privacy policy supersedes any previously adopted policy and is subject to change at any time. We also invite you to consult it regularly on our Website(s) and possible application(s) to take note of any updates.

1. On what occasion(s) does AGORA collect your personal data?

AGORA collects and processes your personal data, subject to your consent when this is required, during the achievement of its corporate purpose, namely in particular and without limitation, planning and developing the urban areas of the BELVAL and METZESCHMELZ sites.

The collection and processing of this data also occurs when it allows it to pursue its legitimate interests or to comply with legal and/or regulatory obligations.

More specifically, these occasions include:

  • When you contact AGORA through one of our electronic media, including:
  • The website www.agora.lu,
  • The corresponding social media pages and mobile applications: Twitter, LinkedIn, YouTube, Facebook, Instagram (hereinafter collectively, for convenience, our “Social Media”),
  • Our correspondence, including electronic messages (including via MailChimp – The Rocket Science Group; LLC; 675 Ponce de Leon Ave NE, Suite 5000, Atlanta, GA 30308 USA); https://mailchimp.com/legal/privacy ), our postal letters, simple or secure, our telephone exchanges as well as, more generally, any documentation exchanged with you,
  • When you participate in procedures for calls for tenders, submissions, purchasing, recruitment, etc., during postal exchanges or the execution of a contract, during meetings of work or during telephone interviews, etc. This includes information that you provide to us directly or indirectly through third parties.
  • When you provide us with documentation, even advertising, containing personal data (business cards, etc.),
  • When AGORA sends you an invitation to one of the events it organises (Meet Up, Mipim, Forums, mailing list, etc.) or when it carries out an information campaign or distributes documentation, advertising or informative, in connection with its corporate purpose,
  • When AGORA analyses or has analysed the preferences of our web users in order to prepare trend reports on how our digital content is used, in order to improve our services.

What type of personal data do we collect and process?

AGORA may process all data that you have communicated directly or indirectly and, in particular, the following categories of data:

general information about you and contact information;

your name, your gender, your address (home/office), your telephone numbers, your email addresses, your nationality, your date of birth, and if applicable, if our exchanges involve the creation of a personal account or your registration form, your identification data;

our interactions with you;

remarks, complaints, compliments, advice or claims you have made, any responses provided by AGORA, interactions with us and our staff (incl. in person, online, by telephone or by e-mail and via networks social);

Browsing information

Where applicable, subject to your consent, information regarding your browsing behaviour on our Websites and any other applications, when you click on one of our advertisements and how you access our digital services, including the operating system, IP address, online identifiers and browser details.

Who processes your personal data that we collect?

We may communicate your personal data to the following categories of third parties:

Support service providers or subcontractors:

To provide our services, we use support or additional services from third parties and subcontractors, e.g. IT suppliers, communication or marketing agencies, law firms, notaries, etc.

Public, administrative and judicial authorities:

Due to current regulations, we may disclose your personal data to public authorities, such as tax or social services, courts or any public order body or agency responsible for the resolution of disputes, legal proceedings and law enforcement,

Third party websites:

Our Websites may contain links to third party websites. If you click on these links, you will leave our Websites or mobile applications. This privacy policy does not apply to third party websites. To find out more about how they process your personal data, please see their privacy and/or cookies policy (if applicable).

Where is your personal data sent?

Your personal data may be stored and processed in any country in the European Union in which we have facilities or use service providers (for more information please see the “Legal Notices” section of our Websites).

How long do we keep your personal data?

The retention periods that AGORA applies take into account the laws and regulations which impose a specific retention period for certain categories of data, as well as the recommendations of the CNPD concerning certain types of data processing. These retention periods can be up to 10 years. We may also archive your data until the legal limitation periods have expired (up to 30 years in certain cases), for reasons directly related to the establishment, exercise or defence of a legal right.

Except in cases where the applicable regulations provide for a longer retention period, we endeavour not to retain your personal data beyond a period of thirteen (13) months from their last transmission.

What measures are taken to ensure the security of the collection and processing of personal data?

In order to guarantee security for the collection of personal data, AGORA has implemented SSL (Secure Socket Layer) certificates on its Websites. These certificates guarantee the encryption of data exchanges between your browser and AGORA web servers.

What are your rights under the GDPR?

AGORA intends to summarise, below, the rights granted to you by the regulations in force regarding the collection and processing of personal data:

  • You have the right to ask AGORA for access and rectification of your personal data. Please note that when you request access to this data, as permitted by law, we may ask you, before the requested information is provided, to specify precisely the information or processing activities in relation to which the request is being made.
  • Subject to the conditions imposed by law, you also have the right to request erasure of your personal data or restriction of processing concerning your data, to object to the processing of your personal data and to request portability of your personal data.
  • You have a right to the portability of your personal data, which enables you to receive the personal data you did not provide to us yourself, in a structured format that is currently used and machine-readable, and, if technically possible, to have these personal data transmitted to a third party.
  • If you have consented to the processing of your personal data, you can withdraw your consent at any time. You can also object, free of charge, to the future processing of your personal data for marketing purposes. in a structured, commonly used and machine-readable format and, if technically possible, to have this personal data transmitted to a third party.
  • If you wish to request to consult, rectify, update or erase your personal data or to limit or oppose the processing, or if you wish to receive an electronic copy of your personal data, you can contact the Data Protection Officer given under the conditions and according to the methods specified below.

How to contact AGORA about its Data Privacy Policy

In order to ensure compliance with the GDPR and the effectiveness of your rights, as set out above, we inform you that AGORA has appointed a Data Protection Officer, who you can contact:

  • By post at the following address:

Development company AGORA S.à r.l. et Cie
Attention: Délégué à la Protection des Données
3, avenue du Rock’n’ Roll
L-4361 Esch-sur-Alzette

How to contact the National Commission for Data Protection

If you wish to lodge a complaint relating to the processing of your personal data by AGORA, you can contact the data protection supervisory authority in Luxembourg at the following address:

National Commission for Data Protection
, avenue du Rock ‘n’ Roll
L-4361 Esch-sur-Alzette

Website: https://cnpd.public.lu/fr.html

What is AGORA’s policy regarding cookie management and data tracking?

Cookies are stored on your computer when you use our Websites directly or through the information campaigns that we organise via the social networks that we implement. Cookies are small text files that are stored on your hard drive in the browser you are using and through which certain information travels to the location that sets the cookie. Cookies are used to make Services more user-friendly and more efficient.

Our Websites use several types of cookies: session cookies and persistent cookies, necessary or not necessary, analytical cookies (including in connection with the use of the social networks that we use).

Session cookies are automatically deleted when you close your browser. Persistent cookies are automatically deleted after a specified period, which may vary depending on the cookie. You can delete the cookies of your choice at any time in the security settings of your browser (see section Making your choices on your browser below).

You can also configure your browser settings according to your preferences and needs. Please note that depending on your choices you may not be able to use all the functions of our Websites.

Analysis and tracing tools

On the site www.agora.lu exclusively, we use the following analysis and tracking tools to measure the effectiveness of our information campaigns and analyse the traffic generated to www.agora.lu from the social networks that we let’s implement:

LinkedIn Insight tag:

The LinkedIn Insight tag collects data regarding members’ visits to the website www.agora.lu, such as URL, referrer, IP address, device and browser characteristics (user agent) and timestamp. IP addresses are truncated or (when used to reach members across devices) encrypted and direct member identifiers are deleted within seven days to make the data pseudonymous. The remaining pseudonymous data is then deleted within 180 days.


LinkedIn does not share personal data with the website owner, it only provides reports and alerts (which do not identify you) on website audience and ad performance. LinkedIn also offers to retarget website visitors, allowing the site owner to display personalised advertisements on their website using this data, but without identifying the member. We also use data that does not identify you to improve the relevance of ads and reach members across devices. LinkedIn members can control the use of their personal data for advertising purposes in their account settings.

For more information on LinkedIn Insight tag, please consult the following link:
https://www.linkedin.com/help/lms/answer/81847/questions-frequentes-sur-le-linkedin-insight-tag?lang=fr

Through the use of these tools, we use the data provided to compile the following statistics in such a way that the data used cannot be attributed to a specific data subject without the use of additional information (Article 4 (5) – REGULATION (EU) 2016/679):

  • Traffic
  • Interaction and engagement – clicks, sharing, comments, reactions…
  • Geographic data
  • Demographic data
  • Video performances

Using Matomo (formerly Piwik):

Our Websites use the Matomo web analytics service to analyse traffic and regularly improve the use of our Websites. Cookies are stored on your computer for this evaluation. You can configure your browser settings by deleting existing cookies and preventing the storage of these cookies. If you prevent the storage of these cookies, we would like to point out that you may not be able to use this Website in its entirety.

More information: https://matomo.org.

How to make your choices

How to make your choices Make your choices from the settings tool

Agora provides you with a simple tool which allows you at any time to configure the storing of cookies or the use of analysis or tracking tools according to their category: Necessary, Functional, Performance, Analytical, Advertising, Others.

The choices you make using this tool are only valid when browsing Agora’s Websites.

By default, all categories and their contents are activated when you click “Accept” in the information message generated on the Websites’ home page. By this action you explicitly declare that you consent to them and accept their activation.

Customize privacy settings

Make your choices on your browser

You can also make your choices regarding cookies on your computer’s browser software. In this case, your choices will apply to all your internet browsing and not just to our Websites.

You can configure your browser software either so that the acceptance or refusal of cookies is offered to you occasionally, before a cookie is likely to be recorded, or to systematically accept or refuse the recording of cookies on your device.

We alert you to the fact that any settings on your browser software concerning the refusal of technical and functional cookies may alter your browsing experience on Agora’s Websites, or even prevent the use of certain services requiring the use of these same cookies.

Where applicable, we decline all responsibility for the consequences linked to the degraded functioning of Agora’s Websites and our services resulting from us being unable to record or consult the cookies necessary for their operation and which you have refused or deleted.

The configuration of each browser is different for managing cookies and your choices. It is described in the help menu of your browser, which will explain how to modify your cookie preferences.

Using social media plug-ins

We use the following social media plug-ins: Twitter, LinkedIn, YouTube, Facebook, Instagram. We have no influence on the data collected and the data processing procedures used by these social media and assume no liability for their use. These plug-ins allow you to access our social media pages and subscribe to News Feeds. They also allow social media platforms (Twitter, LinkedIn, YouTube, Facebook, Instagram) to place cookies on your internet browser and to access them, in particular when you interact with these platforms via plug-ins placed on our Websites. These cookies allow social media to identify you and track your activity on the internet for the purposes of targeted advertising, analysis or market research.

Argis

AGORA makes a virtual scale model available on its website using the ARCGIS and ESRI software.