Privacy policy

A. WHAT TYPE(S) OF DATA DO WE COLLECT? WHY AND ON WHAT LEGAL BASIS?

I. WHAT DATA?

I. Cookie Management

Necessary
Necessary cookies are absolutely essential for the proper functioning of the website. This category only includes cookies that ensure basic functionalities and security features of the site. These cookies do not store any personal information.

Non-necessary
Non-necessary cookies are those that are not particularly required for the website to function and that are used specifically to collect users’ personal data via analytics, advertising, or other embedded content.
It is mandatory to obtain the user’s consent before placing these cookies on the website.

Other
Other cookies used by the website.

Analytics
These cookies are used to track visitor statistics on the website.

II. Access Data (Logfiles)

Date and time of the visit; name of the page visited; amount of data accessed; IP address; referring URL; browser type; browser version; user operating system; internet service provider, etc.

III. Contact Form

Name; email; phone number; and any other personal data included in the “comment” field.

II. WHO IS CONCERNED?

All users of our website.

III. WHY AND ON WHAT LEGAL BASIS?

I. Cookies

Our cookies allow us to adapt the content of our website by analyzing traffic based on your usage habits and preferences.

A cookie is a small file downloaded onto your browser when you visit certain websites. Cookies enable a site to recognize your preferences, which helps provide a more user-friendly browsing experience. For example, cookies allow us to remember your language preferences so you do not need to set them again at each visit.

Each cookie generally contains:

  • The name of the server from which the cookie was sent;

  • The lifetime of the cookie;

  • A value — usually a randomly generated unique number.

The server that sends the cookie uses this number to recognize you when you return to our site or navigate from one page to another.

You can delete all cookies already stored on your computer and configure most browsers to block them. However, in this case, you may need to manually set certain preferences each time you visit a site, and some services or features may not work properly.

Further information about cookie settings
How to manage your choices depending on the browser you use:
Each browser has a different configuration for managing cookies and preferences. You can find this information in your browser’s help menu, which will tell you how to modify your cookie settings.

Legal basis: Depending on the type of cookies (necessary, preference, or marketing), processing is based either on our legitimate interest in improving the content of our website, or on your consent for preference and marketing cookies.

II. To Offer You a More Personalized and User-Friendly Browsing Experience

When you visit our website, information relating to your visit is stored in so-called “logfiles” on the server. These data are used exclusively for statistical purposes and to make our website more user-friendly.
However, we also reserve the right to analyze these logfiles in more detail in the event of a concrete suspicion of illegal use of our website.

Legal basis: Our legitimate interest in improving the content and usability of our website.

III. To Respond to Your Requests via the Contact Form

We must process certain personal data in order to respond to your queries and serve you in the best possible way.

Legal basis: The performance of pre-contractual measures taken at your request.

B. DATA RETENTION PERIOD

We are committed to retaining your personal data only for as long as necessary to fulfill our mission or the purpose for which it was collected.

However, certain personal data may be retained for a longer period as required by law or for the time necessary to handle potential legal proceedings.

Regarding cookies, retention periods are specified in our cookie-management tool.

We will also retain your personal data for as long as necessary to assert our rights in the event of potential legal action or investigation related to our services.

C. PERSONS WITH WHOM WE SHARE YOUR DATA

Google Analytics:
Our website uses Google Analytics, a web analysis service provided by Google Inc. (“Google”).
Google Analytics uses cookies to help the publisher analyze how users use the site.
The data generated by cookies (including the user’s IP address, truncated before storage using the “_anonymizeIp()” method) are transmitted to and stored by Google on servers in the United States.

Google uses this information to evaluate how users use the website, compile reports on site activity for the publisher and administrators, and provide other services relating to website activity and Internet usage.
Google may transfer this data to third parties where required by law or when such third parties process the data on Google’s behalf.
Google will not associate the user’s IP address with any other data held by Google.

By using the site, the user expressly consents to the processing of their data by Google as described above.
If the user does not consent, they must modify their cookie settings in their browser as explained below.

The user can choose to disable Google Analytics tracking on this website by clicking a link that places an opt-out cookie on the user’s device, preventing session tracking as long as the cookie remains stored.

Google Maps:
The website may use the Google Maps API, a mapping service provided by Google Inc. (“Google”), to display geographic information as visual maps.
Using Google Maps entails the collection of information about map usage, which is stored in cookies and transmitted to Google.
For more information on how Google processes and uses this data, please refer to Google’s Privacy Policy, where users can also adjust their privacy settings for Google services.

Our staff who need access to personal data to process your requests efficiently.

Data center (website hosting):
For technical reasons related to reliability and security, we may store personal data in locations not under our direct control (e.g., on servers in data centers, with Internet providers, or on backup servers).
Our website is hosted in a data center located in the Netherlands.

D. TRANSFER OF YOUR DATA TO THIRD COUNTRIES (OUTSIDE THE EUROPEAN ECONOMIC AREA)

As a rule, we do not share, transfer, or otherwise disclose your personal data to countries outside the European Economic Area, unless required by law, by contractual necessity, or with your explicit consent.

In the event of a transfer to a third country, we will inform you in advance of the appropriate safeguards implemented to best protect your personal data.

E. PROTECTION OF YOUR DATA

We apply a range of technical and organizational measures to protect your personal data and to limit the risks of destruction, loss, alteration, unauthorized access, or unauthorized processing.
These include physical, electronic, and managerial measures to ensure the security, accuracy, and integrity of your personal data.

Such measures include:

  • Training and awareness programs for staff to ensure they understand privacy obligations when handling personal data.

  • Administrative and technical controls restricting access to personal data on a strict “need-to-know” basis.

  • Technological security measures such as firewalls, encryption, and antivirus software.
    For example, we use Secure Sockets Layer (SSL) encryption to secure personal information before it is transmitted online.

These security measures are periodically reviewed and updated to maintain an appropriate level of protection.

F. YOUR RIGHTS

You have a number of rights regarding your personal data. Subject to the applicable legal provisions, you have the right:

  • To obtain a list of the personal data we hold about you (right of access).

  • To request that we update or correct any personal data you consider inaccurate or incomplete (right to rectification).

  • Under the conditions of Article 17 GDPR, to request the deletion of your personal data as soon as possible (right to erasure / right to be forgotten).

  • To request that we delete or restrict the way we process your personal data, subject to the legal obligations we are bound by (right to restriction of processing).

  • To withdraw your consent to processing where processing is based on consent (right to withdraw consent).

  • To receive a copy of your personal data that you have provided to us, in a structured, commonly used, and machine-readable format, and to transmit those data to another controller (right to data portability).

  • To object to the processing of your personal data (right to object).

  • In certain cases, not to be subject to a decision based solely on automated processing, including profiling, that produces legal effects or similarly significant impacts (automated individual decision-making, including profiling).

If you are not satisfied with how we process your personal data, you have the right to lodge a complaint with the supervisory authority in your jurisdiction.
In Luxembourg, this is the Commission Nationale pour la Protection des Données (CNPD).

To exercise your rights or file a complaint, please send a written, dated, and signed request together with a copy of your ID card to: mail@onj.lu

G. CHANGES TO THIS PRIVACY POLICY

We may amend or update this privacy policy from time to time — for example, due to legislative changes, the development of new services, or adjustments to how we process personal data.

To keep you informed, we will update the revision date at the top of the page.
The amended or updated version will apply from that date onward.

We encourage you to review this privacy policy periodically to stay informed of any changes.
All our contacts will also receive the updated version by email, together with a summary of the changes made.

H. CONTACT US

If you require further information about how onj.lu uses your personal data, or if you wish to obtain a PDF copy of this privacy policy, please contact us at:
📧 mail@onj.lu