​Last Updated: February 1, 2025 

 

1. Introduction
Lëtzebuerger Scouten Gemeng Nidderaanwen, a.s.b.l. ("we," "our," or "us") is a non-profit organization dedicated to promoting scouting activities for boys and girls. We are committed to protecting your privacy and processing personal data responsibly in line with the General Data Protection Regulation (GDPR). This policy explains our data practices, including our public website, internal photo archive, and email communications.

2. Data Controller
The data controller is Lëtzebuerger Scouten Gemeng Nidderaanwen, a.s.b.l., located at 33, Zone Industrielle Breedewuess L-1259 Senningerberg, Luxembourg. For any privacy inquiries, please contact us at gdpr@scouten.lu.

3. Data Collection and Processing Overview

A. Public Website (Hosted on Wix)
Our website www.scouten.lu, hosted on Wix, provides information about our organization. The website uses contact forms for inquiries and registration forms for event sign-ups, described below.

• Cookies and Analytics: Wix may collect general visitor data (e.g., IP address, browser type) through cookies for analytics purposes, which help improve our website. You can manage cookie preferences in your browser settings.

B. Contact and Registration Forms
The website has contact and registration forms for event sign-ups and general inquiries. Information collected through these forms is used solely to respond to inquiries and manage event participation. Data collected may include:

• Personal Information: Name, contact details (email, phone), and any additional information you provide on the forms.

• Event-Specific Information: For event registrations, we may ask for additional details such as emergency contact information or relevant health information for event planning and safety.

Purpose and Lawful Basis:

• The data collected via contact and registration forms is processed under our legitimate interest in managing inquiries and organizing events.

• Consent: For any sensitive data (such as health information) provided in event registrations, we obtain your explicit consent, and you may withdraw this consent at any time by contacting us.

Data Retention:

• Contact form inquiries are retained for up to 1 year to assist with follow-up communications and then securely deleted.

• Event registration data is retained only for the duration of the event and relevant follow-up period. Emergency contact and health information is deleted after the event concludes.

C. Photo Archive on Private Synology NAS
We maintain an internal photo archive documenting our history and activities, securely stored on a Synology NAS with limited access and facial recognition technology. This archive is for internal purposes only and is not linked to our website.

• Photos of Members and Events: Photos of current and former members are stored to document our history.

• Facial Recognition: Our Synology NAS uses facial recognition for internal organization. This data is not shared and is used solely for photo organization within the NAS.

• Right to Request Deletion: Members may request deletion of specific photos by contacting gdpr@scouten.lu. We will remove photos, subject to historical or legal obligations.

D. Member Lists and Email Communication
We maintain member lists to manage organizational activities and keep members informed. We use Gmail as our email service, and we maintain email distribution groups.

• Member Data: Our lists contain names and contact details. For minors, we may also collect parent/guardian contact information.

• Email Distribution: Emails are used solely for organization-related communication, such as event updates and newsletters.

• Lawful Basis: We process member data under our legitimate interest in managing our organization. For minors, consent from parents/guardians is obtained.

4. Data Security Measures

We are committed to protecting personal data through the following measures:

• Encryption: Our Synology NAS and member data storage are encrypted.

• Access Control: Access to member lists, the photo archive, and email distribution groups is limited to authorized personnel.

• Secure Transmission: Gmail’s built-in security features help protect email data, but note that no transmission is fully secure.

5. Data Retention

We retain personal data only as long as necessary for our organizational needs and legal compliance.

• Photo Archive: Retained indefinitely for historical documentation unless deletion is specifically requested.

• Member Lists: Updated as members join or leave. Data for former members is retained only as required for archival or organizational needs.

• Contact and Event Data: Contact inquiries are deleted after 1 year, and event data (including health information) is deleted once no longer needed.

6. Your GDPR Rights

You have the following rights regarding your personal data:

• Access: Request access to your personal data.

• Rectification: Request correction of inaccuracies.

• Erasure (Right to be Forgotten): Request deletion of your data, including photos, by contacting gdpr@scouten.lu.

• Restriction of Processing: Request limited processing of your data.

• Data Portability: Request a copy of your data in a machine-readable format.

• Objection: Object to processing based on legitimate interest if it impacts your rights.

• Withdraw Consent: Withdraw consent where processing relies on consent (e.g., health data for events).

To exercise these rights, please contact gdpr@scouten.lu.

7. Changes to This Privacy Policy

We may update this Privacy Policy as needed. Updates will be posted on our website or directly communicated to members.

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Contact Information
For any questions or privacy-related concerns, please contact:

Lëtzebuerger Scouten Gemeng Nidderaanwen, a.s.b.l.
33, Breedewuess L-1259 Senningerberg, Luxembourg
gdpr@scouten.lu​​