Privacy policy

Data controller

Petzerhiel S.à r.l.-S — commercial brand LuxHawk
HQ
11, Rue Eugène Ruppert
L-2453 Luxembourg
Luxembourg

Email: info@luxhawk.lu
Telephone: (+352) 27 52 67 45

Data collected

The public website uses technical cookies required for it to operate and an internal measurement of how it is consulted, carried out on the server.

The session cookie protects the contact form. It is used when you send a message and disappears when the browser is closed.

The language cookie luxhawk_lang stores the language selected in the selector: fr, en, de or lb.

During a training session, your phone keeps a technical cookie specific to that session (lh_part_…). It allows your answers and your pseudonym to be found again from one page to the next; it contains neither your name nor your address, and it expires twelve hours after it is set.

Usage is measured on the server, with no cookie, no script and no third-party service. It counts page views per day, page and language, and links the pages consulted during a single visit, with the time of each page, in order to know which pages lead to a contact request. To link those pages, the server computes a visit key from your IP address and your browser’s signature, using a random secret renewed every day and destroyed the next day. This measurement records neither the IP address, nor the browser signature, nor the address of the website you came from; it keeps only a category of origin — search engine, link from another website, direct access, a page of this website itself. The key never links two days and cannot recognise you from one day to the next. Each night, the previous day’s traces are reduced to totals — visits, page views, time between two pages, most frequent paths, per day and per language — and then erased; they are never kept for more than seven days. This measurement helps follow general website consultation without identifying visitors. If your browser sends the Global Privacy Control or Do Not Track signal, your visit is not linked from one page to the next.

What we process, and why

Your browsing

LuxHawk processes only the technical information required for the website to operate, for language selection and for the measurement described above. This measurement is based on LuxHawk’s legitimate interest in knowing how its own website is consulted; it is not cross-referenced with any other data, is used for no decision concerning you, and is read only by the website’s publisher. Since nothing allows us to recognise you beyond the day, an objection can only apply to the future: the Global Privacy Control or Do Not Track signal of your browser is enough, and we ask you for no information to apply it.

The web server also keeps a technical log of requests, which includes the IP address; it is used for security and fault diagnosis, is kept for fourteen days and is never cross-referenced with the consultation measurement.

Your language

The luxhawk_lang cookie stores your language choice. You can delete it in your browser; the website will then return to French.

Your message

When you use the contact form, LuxHawk processes the information entered: first name, last name, email address, telephone number if provided, subject and message. The IP address is used at the time of sending to limit the number of messages per connection; it is not recorded with the message. This information is used to process your request.

Processing your message relies on Article 6(1)(b) GDPR: answering a request you make is a step taken at your request, not processing that requires your consent. The information notice shown to you at the time of submission is recorded separately from the message, so that LuxHawk can show what you were told.

Your participation in training

Answers given during training — quizzes, practical cases and satisfaction questionnaire — are recorded under a pseudonym assigned by the system.

This pseudonym allows you to take part in the exercises and consult a personal summary if you wish. Individual answers remain separate from contact details.

At the end of the session, email follow-up is possible if you choose to provide your email address. This address is processed separately from the answers given during training.

Retention periods

Answers given during training are kept for ninety days after the session date. After that, only aggregated statistics remain.

Contact messages are kept for ninety days after receipt.

Visit traces are erased once reduced to totals, at the latest seven days after the visit. Traffic totals — per day, page, language and path — are kept for twenty-five months at most.

These records of information are kept for five years, under the accountability obligation (Article 5(2) GDPR). At the end of this period, elements that can identify a person are deleted.

You may request deletion of your data before these deadlines by writing to info@luxhawk.lu.

Processing and hosting

Processing is carried out by Petzerhiel S.à r.l.-S. The website is hosted by Infomaniak Network SA in Switzerland.

Your rights

Under the GDPR, you have the following rights:

To exercise these rights: info@luxhawk.lu

Supervisory authority

Commission nationale pour la protection des données (CNPD)
15, boulevard du Jazz
L-4370 Belvaux
Luxembourg