Privacy Notice

Effective date: May 23, 2019

1. General

We the “Parliamentary Group PIRATEN” (hereinafter "us", "we", "our" or “PGP”) operates the https://www.fro.lu website (hereinafter referred to as the "service" or “website”). This privacy notice is intended to explain what personal data we collect from you and how we use this data to operate this service.

Should you decide to create an account and/or interact with our service we act as a “Data Controller” and hence are required to secure your data, respect and protect your privacy.

2. Key Definitions

In order to ensure this notice is clear and understandable, we provide you an explanation of key privacy jargon below. Should you have any questions, do not hesitate to contact us at “privacy@fro.lu”, we are more than happy to clarify any questions you may have.

• “Personal data” represents any information which relates to a living, identifiable physical person. It can include names, addresses, telephone numbers, email addresses, but it is wider than that and includes any other information relating to that person or a combination of information which, if put together, would result in identifying that person.
• “Special category data” means personal data about a person’s race, ethnic origin, politics, religion, trade union membership, genetics, biometrics (where used for ID purposes), health, sex life or sexual orientation.
• “Data subject” means the person whose personal data is being processed.
• “Data controller” means the organisation which is responsible for processing data and ensuring that personal data is processed in accordance with data protection law.
• “Processing” covers all activities relating to the use of personal data by an organisation, from its collection through to its storage and disposal and everything in between.
• “Cookies” are small pieces of information that a website registers with your Browser while you are viewing a web site. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them). Persistent Cookies can be removed by following Internet browser help file directions.

3. Privacy Notices

Personal data must be processed in accordance with specific principles set out in Data Protection Law. These include the principle that personal data should be processed ‘lawfully, fairly and in a transparent manner’.

In order to comply with this principle, the PGP has created this notice to clarify how it will process your information at the time it collects it.

4. Our Principles regarding data protection and privacy

• We believe privacy and data protection is a human right
• We take securing and protecting your privacy serious
• We will only collect and process data when it is necessary, and when we do, we will make it clear why we are doing so and how your data will be used
• We will not share your information with anyone else without your permission, unless required to do so by law.

5. How we collect personal data

Data you provide to us

You are providing data to us in order to create an online account (“Username”, “Email Address”, “Password”, “Fullname” . This data is used to authenticate you to our website and allows you to use the service. In case you choose to Vote or propose a Parliamentary Question you will also share the “Vote” itself and the “Question” with us.

This data is only used for the purpose of offering the service, it is not used for any other purpose. If you choose to share your opinion via a comment, we will also store and display that comment. You can choose to enter your full name, but you don't have to (We don't really need it to offer this service). However should you choose to enter your full name, your Full Name will be part of the processing of your personal data. You may subscribe to a News Digest which automatically sends you a regular summary of new questions and comments. We may also inform you of new features from time to time.

Data we collect automatically or via automated processes

1. As you connect to our website you automatically transmit personal data, amongst others IP Address, Referer etc. If you are interested in knowing which data your browser is sending to website you can visit the following website.
2. Log Files. As is true of most websites, we gather certain information automatically and store it in log files. This information includes IP addresses, browser type Internet service Provider (“ISP”), referring/exit pages, operating system, date/time stamp. We use this information to prevent fake votes and administer the site
3. Cookies. If you register an account and/or login to your account a “Cookie” is registered with your browser. This is required in order for the site to work, recognise you and prevent fraudulent votes.
4. Anti Automation (“Bot Protection”) If you decide to create an account with us, you will have to pass a re-captcha verification step. This is a security feature aimed at protecting Fro.lu from automated bots. re-captcha is a service offered by Google - Googles Privacy Policy can be found at https://policies.google.com/privacy?hl=en With this service, we can differentiate between information that has been entered into a form by a human and information that has been entered by an automated machine. The use of automated information entry constitutes misuse. The IP address transferred by reCAPTCHA is not commingled with other data by Google unless you are logged-in to your Google account at the time when you are using the reCAPTCHA plug-in. If you want to prevent this transfer and storage of data by Google about you and your behaviour on our website, you must log out of Google before you visit our website and/or use the reCAPTCHA plug-in. The information obtained via the reCAPTCHA service is used in accordance with Google's Usage Terms and Conditions: https://policies.google.com/privacy?hl=en

6. Why we collect your personal data

The data we collect is solely and exclusively used to offer the service provided on this website. Our aim is to improve Government transparency and democracy by allowing you to propose Parliamentary Questions and vote on others.

7. Data Transfer

We do not directly share data with any third party, we do not sell your data. We do use links to social media in order to allow easy promotion of questions, the data that your browser shares will only be shared once you click the button.

8. Retention Period

Your personal data will not be kept for longer than is necessary to fulfil the specific purposes outlined in this Notice. There may be legal requirements to store data for a longer period of time in which case we comply with these legal requirements.

9. Your Rights

Under certain circumstances, by law you have the right to:

• Request access to your personal data (commonly known as a "subject access request"). This enables you to receive a copy of your personal data.
• Request correction of your data. This enables you to ask us to correct any incomplete or inaccurate information we hold about you.
• Request erasure of your data. This enables you to ask us to delete or remove your data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your data where you have exercised your right to object to processing (see below).
• Object to processing of your data where we are processing it to meet our public interest tasks or legitimate interests (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your data for direct marketing purposes.
• Request the restriction of processing of your data. This enables you to ask us to suspend the processing of your data, for example if you want us to establish its accuracy or the reason for processing it.

Should you wish to exercise any of your rights (or if you have questions about your rights), please address your request and/or questions to us at privacy@fro.lu

10. Your consent

Where the legal basis for us processing your personal data is that you have provided your consent, you may withdraw your consent at any time. You will not suffer any detriment for withdrawing your consent.

You can withdraw your consent by contacting us at the address(es) below.

11. Contact

privacy@fro.lu

Sensibilité politique PIRATEN
25, rue Notre Dame
L-2240 Luxembourg

12. Changes

This privacy notice was last updated on 23 May 2019. We reserve the right to update this privacy notice at any time. Any changes to this privacy notice will be posted to this page.