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General Data Protection Regulation (GDPR) – Data Protection Web Policy


Luxembourg Stock Exchange (“LuxSE”) is dedicated to deal with and process your Personal Data (as defined in point 1 below) with due care, in confidence and in accordance with the requirements of the General Data Protection Regulation.
Summary

1. Data Protection – Key definitions and principles

GDPR: the General Data Protection Regulation (EU) 2016/679 is an EU regulation on personal data protection and privacy. GDPR achieves the uniformity in the data protection rules applicable to all individuals within the European Union.

Personal Data: any information related to an identified individual or that may allow to directly or indirectly identify an individual (e.g. name, phone number, job title). Personal Data does not include any information or data related to legal entities (e.g. investment funds, securities issuers…).

Processing: any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means (e.g. collection, recording, organization, storage, consultation).

Data controller: the person or entity that determines the purpose and means of the processing of the Personal Data.

2. Scope of Policy

The present Data Protection Web Policy (the “Policy”) does not apply to any processing of your Personal Data by LuxSE when you are a client, a commercial counterparty, a provider or supplier, an employee or any person with who LuxSE has established or is in the process of setting up any contractual, legal or commercial relationship.

The Policy only explains how and why LuxSE collects and uses your Personal Data when:
  • You use LuxSE’s website (the “Website”) or any functionalities or request form available on the Website;  
  • You request the sending of communications or invitations from LuxSE;
  • You register to LGX Academy Webinars; and
  • You send requests to LuxSE by mean of the contact form.
  • In all those cases, LuxSE acts as data controller.

3. Processing of your Personal Data

3.1 Use of the Website

When you use the Website or any functionality of it, LuxSE collects and processes your Personal Data as follows:
  • Purpose of the processing of your Personal Data: LuxSE will process your Personal Data for:
- Obtaining statistical data about the use and access volume of the Website so as to improve the quality and efficiency of LuxSE’s services and create a better experience by enhancing functionalities and by reaching a better user-friendliness level,
- Manage and operate the Website, and
- Make your access to dedicated webpages faster and easier.
  • Collection of your Personal Data: Your Personal Data are collected through cookies (text files which are stored on your computer by your browser), through the information received from your browser, and/ or when you log in to dedicated or personalized pages of the Website.
Please note that LuxSE only uses essential cookies, i.e. cookies intended solely for the purpose of carrying out the transmission of a communication over an electronic communications network or strictly necessary for the provider to supply an information society service expressly requested by the user.
  • Personal Data collected by LuxSE: LuxSE will collect your IP address, the pages of the Website you visit, the duration and time of your visit as well as in some cases, your name, address, phone number and/or email address.
  • Legal ground(s) for the processing of your Personal Data: legitimate interest (as defined by GDPR): management and security of the website.

Any further use of your Personal Data, out of that context, will require a specific consent.

3.2 External communications and invitations

When you request the sending of communications and/ or invitations by LuxSE, LuxSE collects and processes your Personal Data as follows:

  • Purpose of the processing of your Personal Data: LuxSE will process your Personal Data for the sole purpose of sending you communications and/ or invitations (according to your preferences).
  • Collection of your Personal Data: LuxSE will collect your Personal Data when you complete the subscription/ request form for receiving communications and/ or invitations from LuxSE (according to your preferences).
  • Personal Data collected by LuxSE: LuxSE will solely collect the data you provide when completing the subscription/ request form that is to say your name, first name, job title, email address, the name of your company and in some cases your phone number(s). You do not have any obligation to provide whole of the above information and may decide, at your own discretion, to disclose only part of the requested information.
  • Legal ground(s) for the processing of data: consent of the data subject (as defined by GDPR) to the processing of his or her personal data for one or more specific purposes.

Any further use of your Personal Data, out of that context, will require another specific consent.

3.3 Registration for pre-trade and post-trade data

  • Purpose of the processing of your Personal Data: LuxSE will process your Personal Data for the sole purpose of monitoring the access to the pre-trade and post-trade data.
  • Collection of your Personal Data: LuxSE will collect your Personal Data when you complete the contact form.
  • Personal Data collected by LuxSE: LuxSE will collect the data you provide when completing the contact form that is to say your name, first name and email address.
  • Legal ground(s) for the processing of data: consent of the data subject (as defined by GDPR) to the processing of his or her personal data for one or more specific purposes.

3.4 Sending of requests to LuxSE or requesting commercial information
  • Purpose of the processing of your Personal Data: LuxSE will process your Personal Data for the sole purpose of handling your request and provide you with an appropriate answer. Such answer may be, when appropriate, an offer or solicitation to subscribe to services supplied by LuxSE.
  • Collection of your Personal Data: LuxSE will collect your Personal Data when you complete the contact form.
  • Personal Data collected by LuxSE: LuxSE will collect the data you provide when completing a contact or registration form.
Mandatory fields
The processing of your request requires the collection of your personal data, i.e. your title, name, first name, as well as your e-mail address.
Non-mandatory fields
If you consider it necessary and/or relevant, additional information can be added in the non-mandatory fields of the forms, namely your phone number, your company and field of work.
You do not have any obligation to provide whole of the above information and may decide, at your own discretion, to disclose only part of the requested information.
  • Legal ground(s) for the processing of data: consent of the data subject (as defined by GDPR) to the processing of his or her personal data for one or more specific purposes.
Any further use of your Personal Data, out of that context, will require another specific consent.

4. Storage of your Personal Data

LuxSE takes reasonable and appropriate technical and organizational security measures in order to:
  • Store your Personal Data in secure databases or systems with restricted access,
  • Protect your Personal Data against loss, accidental or intentional misuse, alteration, destruction and access by unauthorized persons.
LuxSE will notify you without undue delay in the event LuxSE becomes aware of any unauthorized or improper use, access or disclosure of the Personal Data, which is likely to result in a high risk to your rights and freedoms.

Please kindly note that some of the databases or systems used by LuxSE for mailing services and storage systems may be hosted and/or maintained by third party service providers located inside or outside of the European Union. Your Personal Data will only be disclosed to such service suppliers if LuxSE has deemed, in its reasonable opinion, that such service providers offer appropriate guarantees with regard to confidentiality, security and protection of your Personal Data.

LuxSE also reserves the right to disclose Personal Data to any court, judicial or administrative authority when required or legally compelled to do so.

6. Your right to access, correct and request the deletion of your Personal Data

You have the right to access, modify, correct and/ or request the deletion of your Personal Data at any time as well as to restrict or oppose to the use of your Personal Data for the purposes mentioned above including:
  • For communications and invitation sent by LuxSE: You may withdraw your consent to receive communications or invitations at any time by sending an email to privacy@luxse.com. In that case, LuxSE will immediately cease to send you communications and invitations.
  • For the use of the Website: you may have, at any time, the option to either accept or refuse cookies on the Website by changing the settings of your browser. However, if you choose to refuse cookies, you may not be able to access and use certain portions of the Website. You may also encounter difficulties or restrictions when accessing whole or part of the Website for which LuxSE disclaims any liability or responsibility of any kind.
If any of the Personal Data that you have provided to LuxSE changes or becomes no longer up-to-date, you should send an email to privacy@luxse.com. LuxSE will not be responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete Personal Data that you provided.

7. Amendment to the Policy

The Policy may be amended, replaced, or supplemented at any time and without prior or further notice by LuxSE. You are therefore advised to review it from time to time for any possible changes.

8. Complaints

If you consider that the processing of your personal data by the CNPD infringes the General Data Protection Regulation, you can lodge a complaint with the CNPD.

9. Cookie Policy

This website (the “Website”) uses cookies. Cookies are small text files that can be used by websites to make a user's experience more efficient.

We use cookies to :

  • Obtain statistical data about the use and access volume of the Website so as to improve the quality and efficiency of LuxSE’s services and create a better experience by enhancing functionalities and by reaching a better user-friendliness level,
  • Manage and operate the Website, and
  • Make your access to dedicated webpages faster and easier.

We do not automatically capture or store personal data from browsers to the Website, other than to log your IP address and session information such as the duration and time of your visit and the pages of the Website you visit. This information is used only for administration of the Website and in the compilation of statistics which we use for analysis in order to improve the Website.

In accordance with the law, we can store cookies on your device if they are strictly necessary for the operation of this site. For all other types of cookies we need your consent. This means that cookies which are categorized as necessary, are processed based on GDPR Art. 6 (1) (f). All other cookies, meaning those from the categories statistics and marketing, are processed based on GDPR Art. 6 (1) (a) GDPR.

Strictly necessary cookies are stored in your browser as they are essential for the Website to function. Other cookies further improve your experience and help us analyze how users interact with our Website by collecting anonymous data. For example, they enable you to improve your experience on the Website and enable the Website to remember your actions and preferences. Such cookies allow for a smoother and more tailored browsing experience. 
You can at any time change or withdraw your consent on the following webpage: Manage cookies

The Website uses different types of cookies. Some cookies are placed by third party services that appear on our pages. Below is a list of cookies set on the Website and the purpose of each:

Cookie type Name Provider Description  Lifespan
Essential LuxSE Token
LuxSE
Allow the user to be connected to LuSE's services 12h
Marketing Linkedin Insight tag
LinkedIn
Allow us to reach an audience that already visited our website through Linkedin to create relevant ads 180 days
Statistics Google Analytics 4 Google Monitor the audience's behaviour to know which type of content is viewed
14 months 
Statistics Hotjar Hotjar Allow us to understand users' behaviour 365 days 
Marketing Google Ads Google Allow us to target an audience that already visited our website to create relevant ads
30 days 

Learn more about how we process personal data in our Data Protection Web Policy.

10. Contact

Please feel free to send any queries or requests related to the processing of your Personal Data by LuxSE, in the context described above, to privacy@luxse.com.
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