Introductory Remarks

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TOGETHER FOR CHILDREN a.s.bl., is a non-profit organization located at L-1309 (hereinafter referred to as "TOGETHER FOR CHILDREN"), holds the rights authorizing it to operate, throughout the territory of the Grand Duchy of Luxembourg, as a non-profit association.

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TOGETHER FOR CHILDREN, is required, in the course of their activities, to collect and process the personal data of individuals with whom they interact (hereinafter referred to as "Personal Data"), including visitors to their websites, their partners, sponsors or contacts, the directors and employees of corporate clients, prospects or contacts, service providers or suppliers, business partners and/or candidates for employment or collaboration (hereinafter referred to as "Data Subjects").

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Committed to the protection of Personal Data

 

TOGETHER FOR CHILDREN undertakes to ensure the highest level of protection for the data processed in compliance with current national and European regulations.

 

Identity of the Data Controller

 

The data controller is TOGETHER FOR CHILDREN a.s.b.l. with whom the Data Subject interact directly or through our website, social medias, and any other form of interaction.

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Regarding data collected during browsing on this website, the data controller is:

TOGETHER FOR CHILDREN A.S.B.L.

ADRESS: L-1309

E-MAIL: contact@togetherforchildren.eu

 

Types of Data Collected and Data Origin

 

When browsing this website, Data Subjects are required to provide information about themselves, some of which may identify them and therefore constitute Personal Data. This is notably the case for:

Subscription to a program as sponsor

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Contacting TOGETHER FOR CHILDREN, for example, to participate, make donations, etc.

Requesting information or documents

Creating an account in the customer area of ​​this website

Browsing the website or a TOGETHER FOR CHILDREN application

 

The Personal Data that may be collected and processed on this occasion are as follows:

 

• Identity: name, first name, gender, date and place of birth, professional contact details, personal contact details

 

• For business partners: names of directors, positions held, professional contact details

 

• For job applicants: workplaces, names and contact details of previous employers, successive jobs held, projects managed, length of service in various roles, nature of the employment contract, disability rate, recognition of disabled worker status, contact details of a reference person, details of training and qualifications (diplomas, certificates), internships, language skills, school certificates and diplomas, if required in the job offer, collaboration offer, or required during the interview, results of tests/exercises that may be conducted during the recruitment process, additional information (interests, handwritten notes taken by the interviewer during the interview, candidate's cover letter), social media profile if the candidate makes their profile public, photographs if the candidate chooses to include them in their application file, and any other data that the candidate decides to include spontaneously in their application file.

 

Data related to programs, sponsoring and/or donations activity:

• Characteristics of the program, sponsor and/or donation. 

• Family, personal, marital, and professional status (type of activity or employment exercised, under what status, number of children or family members likely to reside or stay in the property sought).

• Passport/ID card references

• Transaction data (payment method, account number)

• Data relating to navigation on this website (Date, time of connection and/or browsing, type of browser used, browser language, IP address)

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Personal Data is collected from information transmitted:

• Directly by Data Subjects (e.g. when they sign a contract with TOGETHER FOR CHILDREN, otherwise contact TOGETHER FOR CHILDREN by email, telephone, or via social networks, fill out a paper form or online form).

• From sources that Data Subjects have evidently chosen to make public, including through social media (e.g. information from social network profile(s) to the extent that the Data Subject decides to make it/them accessible).

• When Data Subjects visit this website operated by TOGETHER FOR CHILDREN or when they use the functions or resources offered on or via this website or an application. When Data Subjects visit this website or use the resources and applications offered on it, their device and browser may automatically disclose various information (device type, operating system, browser type, browser settings, IP address, language settings, dates and times of connections to a website or technological tool, and other technical information relating to communications), some of which may constitute Personal Data.

 

Purposes of Data Processing / Legal Basis of Processing / Data Retention Period

 

The purposes for which Together For Children a.s.b.l. may be required to process Personal Data as well as the legal bases authorizing such processing are as follows:

 

 

Recipients of Personal Data

 

The Personal Data collected are processed internally by duly authorized persons within the limits of their respective responsibilities.

It may also happen that Personal Data is communicated to third parties, namely:

• Together For Children a.s.b.l.

• The direction board of the schools and orphanages we work with.

• Administrative and/or judicial authorities, legal officers, and ministerial officers upon request or if necessary.

• Accountants, lawyers, notaries, bankers, insurers, architects, and other professional advisors upon request or if necessary.

• Third-party service providers processing Personal Data on behalf of TOGETHER FOR CHILDREN (credit card payment management, shipments and deliveries, hosting, data administration and management, email distribution, conducting opinion surveys, research, analysis, and promotion of offers)

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The communication of Personal Data to third parties will only be made to the extent necessary and subject to the existence of contractual guarantees ensuring the security and confidentiality of the transferred data.

 

The transfer of personal data may be made to other countries, which may apply different data protection legislation and requirements, including less restrictive data protection laws than those in force in your country.

 

TOGETHER FOR CHILDREN carries out any transfer of Personal Data to other countries based on:

• decisions of adequacy of the European Commission; or

• appropriate contractual clauses; or

• other approved transfer mechanisms.

 

Outside the cases stated above, TOGETHER FOR CHILDREN undertakes not to sell, rent, transfer, or give third-party access to the data without the prior consent of the data subject, unless required to do so for a legitimate reason (legal obligation, fraud or abuse prevention, exercise of defense rights, etc.).

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Principle Governing the Processing of Personal Data

 

• Data security: TOGETHER FOR CHILDREN implements appropriate technical and organizational security measures to protect the Personal Data of data subjects against accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access, and any other unlawful or unauthorized processing in accordance with applicable law.

 

• Data accuracy: TOGETHER FOR CHILDREN takes all reasonable measures to ensure that:

the Personal Data of data subjects undergoing processing are accurate and, if necessary, updated; and that

this Personal Data, if found to be inaccurate (in relation to the purposes for which it is processed), is immediately erased or rectified.

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• Minimization of data processing: TOGETHER FOR CHILDREN takes all reasonable measures to ensure that the Personal Data of data subjects is limited to the information reasonably required for the purposes pursued.

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• Data retention: TOGETHER FOR CHILDREN and/or our partners take all reasonable measures to ensure that the Personal Data of data subjects is processed only for the minimum period necessary for the purposes pursued. The criteria for determining the period during which TOGETHER FOR CHILDREN. retains the Personal Data of data subjects are as follows:

TOGETHER FOR CHILDREN will retain copies of this Personal Data in a form allowing identification only for the retention period indicated in the table above.

 

To this retention period for Personal Data, the following durations should be added:

- any applicable limitation period under current legislation (i.e., any period during which a person could bring legal action against Together For Children a.s.b.l. in connection with Personal Data of the data subject or in which this data could be relevant); and

- an additional period of six months following the expiry of the applicable limitation period (so that if a person brings legal action at the end of this period, Together For Children a.s.b.l. still has a reasonable time to identify the relevant data in connection with this action).

 

In the event of legal action, TOGETHER FOR CHILDREN will retain the Personal Data of the data subject for the additional periods necessary for the conduct of this action.

 

Once the retention period for Personal Data has expired, TOGETHER FOR CHILDREN may, at its option:

Delete or permanently destroy the relevant Personal Data, or

Archive this Personal Data so that it can no longer be used, or

Make the Personal Data anonymous.

 

Rights of Data Subjects

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Subject to applicable law, and upon production of valid proof of identity, data subjects have the right to exercise certain rights, namely:

 

• The right to request access to, or copies of, their personal data as well as information on how their data is processed.

• The right to request the rectification of any errors affecting their personal data and, where data is incomplete, to provide the missing supplementary data.

• The right to request, for legitimate reasons:

• The erasure of data.

• The transmission of data, in a structured, commonly used, and machine-readable format, for their personal use or for transmission to a third party; however, this right exists only for data processing based on the consent of the data subject, or for processing carried out by automated means.

• The restriction of data processing.

• The right to withdraw their consent when the processing of personal data is based on this consent.

• The right to lodge a complaint with a data protection authority regarding the processing of their personal data.

• Subject to applicable law, data subjects may also have the following additional rights regarding the processing of their personal data:

• The right, for reasons relating to their particular situation, to object to the processing of their personal data.

• The right to object to the processing of their personal data when it is intended for direct marketing purposes.

• To exercise these rights or for any questions regarding the processing of their data, data subjects can contact contact@togetherforchildren.eu.

 

For any information on personal data protection, data subjects can also consult the website of the National Data Protection Commission http://www.cnpd.lu.

 

Modification of the Data Protection Policy

 

The data protection policy applied by TOGETHER FOR CHILDREN may evolve, particularly in light of regulatory, jurisprudential, or technical changes. The date of the last update to the data protection policy applied is indicated at the bottom of this document. It is therefore advisable to regularly consult this page to be informed of any modifications or updates made to this policy.

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February 2024