Privacy policy

VAUBAN is responsible for processing the personal data collected and processed through the Website for the purposes outlined below.

When you use the Website, we collect, or may collect, personal data about you directly from you (e.g. your e-mail address, title, date of birth, postcode) when you:

• create a user account,
• post a comment,
• complete a form, or
• contact one of VAUBAN’s departments or services.

Whether the provision of this personal data is mandatory or optional in order to benefit from these services is indicated on the Website or the relevant form.

Subject to your prior consent in our cookies manager – unless an exemption from consent applies in accordance with the guidelines of Luxembourg’s National Data Protection Commission (CNPD) – we may also collect browsing data during your visits to the Website (for example, your IP address, the type and version of your web browser, the content you have viewed) through the placing and/or reading of cookies on your device (e.g. computer, laptop, tablet, smartphone, smart TV). To find out more about the cookies used on the Website, please refer to our cookies policy, which is available at the following address: www.vauban.lu/politique-des-cookies/.

VAUBAN uses all or part of the data thus collected to achieve one or more of the processing purposes (i.e. the objective for using personal data) outlined below:

• Purpose 1: To create and manage your user account to give you access to your ‘Restricted area’

Your personal data collected directly from you through the Website is processed in order to create and manage your user account in the Restricted area of the Website.

The processing of this data is necessary to administer your account, for example, to:

• authenticate you,
• allow you to change your password,
• ensure that your account remains active for the periods indicated in the various information notices concerning you.

This data processing is necessary for the performance of the contract that you enter into when you accept the terms of the ‘Education contract between the parents and the school’ as well as the other documents regarding the enrolment of your child(ren) (legal basis: the contract).

• Purpose 2: To manage user relationships and facilitate interaction with our visitors

The personal data collected, or that may be collected – either directly from you when you create a user account, complete a form, or indirectly from third-party partners when completing a data-collection form or because you have made such data publicly available online – is processed in order to manage relationships with our users and to facilitate interaction with our audiences.

The processing of this data – excluding data that you choose to make publicly available online – allows us to:

• communicate with you by e-mail or phone,
• inform you about the features available through your user account and VAUBAN’s duties,
• send you VAUBAN’s newsletter(s).

The processing carried out to send you communications is necessary for the purposes of the legitimate interests pursued by VAUBAN in managing relations with its users and audiences through the sending of e-mails as part of welcome and, where applicable, reactivation cycles (legal basis: legitimate interest).

The processing carried out to contact you again via the communication channel you provided is necessary for the purposes of the legitimate interests pursued by VAUBAN in providing you with an appropriate and personalised response to your questions (legal basis: legitimate interest).

• Purpose 3:  To ensure compliance with laws and regulations, as well as the terms of use of VAUBAN’s websites and applications

The personal data collected, or that may be collected, directly from you when you create a user account or complete a form and/or your browsing data (particularly your IP address) is processed to ensure compliance with the laws and regulations in force.

The processing of this data enables VAUBAN to prevent or put an end to prohibited, fraudulent and/or clearly unlawful activities or publications, or to respond to any requests from third parties authorised by law.

The processing carried out to ensure compliance with the laws and regulations in force is necessary to fulfil a legal obligation to which VAUBAN is subject (legal basis: legal obligation).

• Purpose 4:  To manage parent relation services

The personal data collected, or that may be collected, directly from you when you create a user account, complete a contact form or conduct an e-mail or telephone exchange is processed to enable VAUBAN’s staff to fulfil their duties in managing relations with students’ parents.

The processing of this data allows VAUBAN to identify you, contact you again easily and provide you with a suitable response that is tailored to your situation.

This processing is necessary for the purposes of the legitimate interests pursued by VAUBAN in providing its users with top-quality information while responding in a suitable and personalised manner to their questions, comments, complaints, etc. (legal basis: legitimate interest).

• Purpose 5: To respond to requests to exercise rights

Personal data that may be collected directly from you when processing a request to exercise the rights you are entitled to under the General Data Protection Regulation (GDPR) and the Luxembourg Data Protection Act of 1 August 2018 is processed to enable us to respond to these requests.

The processing of this data allows VAUBAN to identify you, contact you again easily and provide you with a suitable response that is tailored to your situation.

This processing is necessary to fulfil a legal obligation to which VAUBAN is subject pursuant to GDPR (legal basis: legal obligation).

• Purpose 6: To manage VAUBAN’ servers

Vauban saves information about your connections to its websites and applications (legal basis: legitimate interest, ensure server security).

To carry out our duties and provide you with all of the services described above, we have to share your data with various stakeholders:

• Vauban’s internal departments. We have to share the data we collect with VAUBAN’s internal departments, which may use them solely in the context of their activities. Only authorised staff have access to the data needed for their department’s activities.
• Our subcontractors and service providers. We may share this data with service providers who process, on our behalf and in accordance with our instructions, the data necessary to provide services in the following areas of activity: administrative, technical and educational support.
• Third parties authorised by law or regulations. In certain cases provided for by law or regulations, we may be required to communicate the necessary data to authorised third parties, such as legal and/or administrative authorities or your internet service provider.

To carry out our duties and provide you with all of the services described above, we have to share your data with various stakeholders:

VAUBAN attaches great importance to protecting the privacy of its youngest users. To this end, students are only authorised to create and access a user account once they start middle school.

The length of time for which your data is kept depends on the purpose for which we collect and process it.

We will keep your personal data in a form that allows you to be identified only for as long as is strictly necessary to fulfil the purposes set out above.

The determination of the retention period for data collected directly or indirectly from you is most often based on an inactivity criterion, such as the date of your last login to your user account or the date of the last contact made with you.

Another criterion we use to determine how long your data is kept for is based on the applicable statutory limitation periods. For example, we may keep some of your data after your user account has been closed if this is necessary to comply with our legal obligations or in order to exercise, defend or assert our rights.

Furthermore, as a general rule, the retention period for your choices regarding cookies placed on the device you use to access the Website is one year from the date they are first placed on your device, pursuant to CNPD guidelines.

In accordance with GDPR, you have the right of access, rectification, erasure, restriction, objection and data portability in relation to your personal data, subject to the limits and conditions set out in the relevant legislation and case law. You also have the right to withdraw your consent at any time to the future processing of your personal data, where such processing is based on consent as its legal basis.

To find out more about the scope of these various rights, please refer to one of the dedicated pages of the CNPD website, accessible at the following address: https://cnpd.public.lu/fr/particuliers/vos-droits.html.

You can exercise your rights in various ways:

• By contacting VAUBAN’s data protection officer at the following e-mail address: dpo@vauban.lu
•  By sending a letter to:

VAUBAN – Data protection

1-3, rue Albert Einstein

L-1484 LUXEMBOURG

Finally, you have the right to lodge a complaint with Luxembourg’s National Data Protection Commission (CNPD) via its website at cnpd.public.lu/fr.html or by post: 15, Boulevard du Jazz, L-4370 Belvaux.

Yes, any amended version of this policy will apply to your use as soon as it is published.

In the event of significant changes, we will inform you by sending a message to the e-mail address you provided us with or by displaying a notice on the Website. We encourage you to consult our privacy policy regularly in order to familiarise yourself with the most recent version.