1. Data controller
This policy explains how we process your personal data.
The data controller is Code Club Luxembourg a.s.b.l., registered with the Luxembourg Business Registers (LBR) under number F9694, 40, boulevard Pierre Dupong, L-1430 Luxembourg. For any questions about your data: dataprotection@codeclub.lu.
2. Data collected
We only collect what you send us:
- The data you enter in our forms.
- Newsletter: email, first name, surname (optional), language and proof of your consent.
- A child’s participation: the child’s name and age and a parent’s contact details, passed on to the club team.
- Volunteers: the criminal record extracts (bulletins No. 3 and No. 5) are viewed but not kept.
- Testimonials and volunteer profiles: name, photo, role and testimonial, published with your agreement via our testimonials tool, which we host ourselves.
3. Purposes and legal bases
We use your data only for the following purposes, each based on a legal basis:
- Responding to your requests (contact, partnership, opening a club): legitimate interest.
- Managing your membership: performance of the membership contract.
- Volunteer applications and publication of testimonials: your consent and the steps taken before you start volunteering.
- Children’s participation and photos: a parent’s consent.
- Newsletter: your consent, which you can withdraw at any time.
- Website security: legitimate interest.
We never sell or give away your data, and we do not carry out any profiling.
4. Recipients
Only the people and service providers who need your data have access to it.
Your data is processed by committee members and, where necessary, by the team of the club concerned. Our service providers:
- ION S.A. (Luxembourg): website hosting;
- Google (Google Workspace): email;
- Mailchimp (The Rocket Science Group LLC, part of Intuit, United States): sending the newsletter;
- Vimeo (Vimeo.com, Inc., United States): playing our videos, only if you choose to load them.
Transfers to the United States are governed by the EU–US Data Privacy Framework and the European Commission’s standard contractual clauses.
5. Newsletter
You only receive our newsletter if you have subscribed to it.
Your subscription is confirmed by a verification email. Mailchimp measures opens and clicks, which we use only to improve our mailings. Every mailing contains an unsubscribe link.
6. Cookies
Our website does not use cookies.
No technical, advertising or analytics cookies are set when you visit.
Our videos are hosted on Vimeo and only load after you click. Vimeo then receives your IP address and may use cookies needed for playback.
7. Retention and security
We do not keep your data longer than necessary.
- Workshop participation: during the workshop, then 6 to 12 months for administrative follow-up.
- Members’ data: during membership, then 1 to 2 years.
- Accounting data: 10 years, in accordance with Luxembourg law.
- Club participant lists: deleted no later than one year after the end of the school year.
- Newsletter: until you unsubscribe.
- Protection against duplicate submissions: an irreversible fingerprint of your submission, deleted after 10 minutes.
Access to your data is limited to the people who need it, our accounts are password-protected and our software is kept up to date.
8. Your rights
You stay in control of your data at all times.
You can access your data, have it rectified or erased, and restrict or object to its processing by writing to dataprotection@codeclub.lu. We reply within one month. You can also lodge a complaint with the Commission nationale pour la protection des données (CNPD, cnpd.public.lu).