Site Presentation
Owner: Stëmm vun der Strooss – Non-profit association – recognized as being of public utility
7 rue de la Fonderie L-1531 Luxembourg – Grand Duchy of Luxembourg

Creator: The Loupe 5, Rue de la Frontière, 9412 Vianden, Luxembourg

Host: Perceval Technologies S.A.
Parc d’Activité – Syrdall I – 9, rue Henri-Tudor L-5366 Münsbach

I. General Terms of Use (GTU) of the website www.stemm.lu

Anyone using the information, documents, products, software, and various services offered by the website www.stemm.lu is deemed to have read and accepted all terms and conditions of these general terms of use. The website www.stemm.lu is regularly updated by Alexandra OXACELAY. The association Stëmm vun der Strooss strives to provide as accurate information as possible on the website www.stemm.lu. However, it cannot be held responsible for omissions, inaccuracies, or shortcomings in the updates, whether due to its own actions or the actions of third-party partners providing the information.

Definition and Purpose
www.stemm.lu is a website created by the Stëmm vun der Strooss association to facilitate users' access to information about the association, its activities, and services, and to allow for donations to support its actions for the most disadvantaged people in Luxembourg.
The use of www.stemm.lu is free of charge.

User Obligations
Copyright: In the absence of contrary indications, reproduction of the information on this site is allowed for non-commercial purposes, provided that the source is explicitly mentioned.
Stëmm vun der Strooss asbl owns intellectual property rights or holds usage rights over all elements accessible on the site, including texts, images, graphics, logos, icons, sounds, and software. Any unauthorized exploitation of the site or any of its elements will be considered an infringement and prosecuted under the provisions of articles L.335-2 and subsequent articles of the Intellectual Property Code.

Access to www.stemm.lu is via the Internet. The user acknowledges the risks and accepts them. They must protect themselves against the effects of hacking by adopting an appropriate and secure computer setup.
Stëmm vun der Strooss cannot be held responsible for any damage that the user may suffer directly or indirectly in relation to their navigation on the website www.stemm.lu and the use of its services, as well as websites linked to it.

Cookie Management
www.stemm.lu uses client cookies, small text files that allow the analysis of user navigation (visit frequency, duration of visits, pages viewed, language preferences, etc.). They are deposited by www.stemm.lu in a directory on the user's computer. They include, in particular, the name of the server that created them, a unique identifier, and an expiration date. Session cookies are deleted from the user’s computer when the session is closed. However, persistent cookies remain on the user’s computer for one month after the session ends.
The user can decide whether or not to allow the website www.stemm.lu to store cookies on their computer. They can adjust their browser settings at any time to prevent cookies from being accepted or stored. Additionally, users can delete cookies that have already been stored through their browser.

Modification of www.stemm.lu
Stëmm vun der Strooss reserves the right to evolve, modify, or suspend the website www.stemm.lu without notice for maintenance, updates, or any other reason deemed necessary. Stëmm vun der Strooss may, at any time, remove, add, complete, or clarify any part of the information and services on the site. No liability for any direct or indirect damage related to such modifications can be held against Stëmm vun der Strooss.

General Limitations of Liability
Stëmm vun der Strooss will ensure the best possible availability of the website www.stemm.lu. However, its responsibility cannot be held in case of a temporary or total unavailability of the site.
Stëmm vun der Strooss will take all reasonable measures to ensure the security of the computer system.
Stëmm vun der Strooss will ensure the best possible accuracy of the information or services on www.stemm.lu and published on social networks. However, its responsibility cannot be held, especially in case of omission of an update, system manipulation errors, inaccuracies, gaps in the provided information, or possible errors in responses. The goal is to provide accurate and up-to-date information from various sources, but Stëmm vun der Strooss cannot avoid all risks of material errors.

www.stemm.lu Responsibility Limitations
Stëmm vun der Strooss's responsibility is expressly excluded for all direct and indirect consequences:

  • Incompatibility between the offered service and the user's or third-party's equipment, applications, procedures, or infrastructure;
  • A security breach originating from the user or a third party, or generally any security breach not directly attributable to www.stemm.lu;
  • The consequences of errors and/or fraud committed by the user or a third party;
  • Potential unavailability or malfunction of communication systems or networks.

Links to Linked Sites
For the convenience of users, the website www.stemm.lu may contain links to other websites that may be useful or interesting to them. Stëmm vun der Strooss does not systematically control the content of these sites. Therefore, it cannot be held responsible for the content presented on these websites, whether in terms of their legality or the accuracy of the information they contain.

Online Payment
Donations can be made via the payment methods offered on www.stemm.lu. Payments are processed by a payment institution registered in the public register approved in Luxembourg, which secures the payment transactions.
Payment data (credit card or account number, payment amount, etc.) does not pass through the Stëmm vun der Strooss site, which never has access to such data. Therefore, it cannot be held responsible for any malfunction of the payment application or for fraudulent use of payment data. The user is subject to the general terms of the payment institution (PayPal or Digicash) for payment.

Modification of Terms and Conditions
These terms and conditions may be modified or supplemented at any time without notice, based on changes to the website www.stemm.lu, legal updates, or any other reason deemed necessary. It is the user's responsibility to stay informed about the general terms of use of the site www.stemm.lu, whose updated version is considered valid. Users are advised to read the updated terms and conditions before each new use.

Applicable Law and Jurisdiction
Any dispute related to the use of the website www.stemm.lu and its services will be governed by Luxembourg law and will fall under the exclusive jurisdiction of the courts of the Grand Duchy of Luxembourg.

II. Personal Data Protection
General Information about www.stemm.lu
Personal data provided by the user is processed in accordance with Regulation (EU) 2016/679 of the European Parliament and the Council of April 27, 2016, on the protection of individuals regarding the processing of personal data and the free movement of such data.
Technical and organizational security measures are implemented by Stëmm vun der Strooss to ensure an appropriate level of confidentiality, integrity, and availability of services offered via www.stemm.lu and to protect the user's rights and freedoms. Only authorized users can access personal data, and this is done for legitimate purposes. User data is stored in the Grand Duchy of Luxembourg.

Users have the right to access, rectify, and erase their personal data. These rights can be exercised with the data controller concerned, and they can be contacted via the Data Protection Officer (DPO) by email at [email protected] or by post at the following address:
7 rue de la Fonderie L-1531 Luxembourg – Grand Duchy of Luxembourg. A valid ID card copy (front/back) must also be provided.

The user also has the right to limit processing, oppose processing, withdraw consent, and request data portability directly from the data controllers.
Users can submit complaints related to their data protection via the respective communication channels available. They can also contact the National Data Protection Commission for any disputes in this area.

Processing related to procedures on www.stemm.lu

The features offered by www.stemm.lu allow users, on a voluntary basis, to generate documents for their own use. When a user submits a procedure to the Stëmm vun der Strooss association, the user's express consent for the processing of their personal data will be requested as part of the procedure and/or request by the association.

The data controller is the Stëmm vun der Strooss association, which has implemented the procedure on www.stemm.lu. Their contact details are available in the "Contact" section, clearly displayed in the header of the site.

When the user electronically submits their form or complete file (form, possible attachments, and supporting documents), the information they have provided is recorded and sent directly to the Stëmm vun der Strooss association.

The extent of the data collected is determined by the legal or regulatory basis on which the request or procedure is based, as well as by the data controller. This data is only accessible to the user and the data controller. However, the user consents to a strictly limited number of persons within the Stëmm vun der Strooss association or subcontractors subject to a non-disclosure agreement temporarily accessing the data of a specific procedure at the user's request, and this access is strictly within the framework of a user assistance request submitted to the [email protected] service or DPO by mail.

As part of the processing of their procedure, the user consents that, if applicable, the transmitted data be duplicated within the data controller's information system. Any future destinations and further processing of the data by the data controllers are not known in advance by the Stëmm vun der Strooss association and are not within its scope. Therefore, it is up to the user to directly contact the data controllers to inquire, if applicable, about the destinations and further processing of their data.

The retention period for the data for each type of procedure is variable and is the responsibility of the data controller. The criteria used to determine this depend on the relevant legal basis.

Event Log Processing

The user consents that data related to their activity on www.stemm.lu (name, surname, procedure or feature used, date and time, parameters) be audited, meaning stored, solely for the purpose of making this data available to the respective data controllers or judicial authorities in the following limited cases:

  • For the resolution of information security incidents, in the legitimate interest of ensuring the security of www.stemm.lu;
  • For the establishment, exercise, or defense of a right in court, in the context of judicial, administrative, or extrajudicial proceedings related to the audited procedure.

The user is informed that the confidentiality of this data is ensured according to the highest standards and that extractions of such data are only possible upon explicit request from the data controller or judicial authorities and only upon a justified request.

Processing related to unauthenticated procedures

The processing related to these features allows a user to submit a procedure without authentication, on a voluntary basis. The user's express consent for the processing of their personal data will be requested as part of their procedure and/or request by the Stëmm vun der Strooss association.

The data controller is the Stëmm vun der Strooss association, which has implemented the relevant procedure. Their contact details are available in the "Contact" section, clearly displayed in the header of the site. Perceval S.A is its sole subcontractor responsible for hosting the www.stemm.lu platform, and The Loupe is the sole subcontractor responsible for its design.

The extent of the data collected is determined by the legal or regulatory basis and by the data controller.

As part of the processing of their procedure, the user consents that, if applicable, the transmitted data be duplicated within the data controller's information system. Therefore, it is the user's responsibility to directly contact the data controllers to inquire, if applicable, about the destinations and further processing of their data.

The retention period for the data for each type of unauthenticated procedure is variable and is the responsibility of the data controller, with the criteria for determining it depending on the relevant legal basis.

It should be noted that the legal bases for unauthenticated procedures may contain specific provisions regarding the exercise of the user's rights.

Processing related to audience measurement on www.stemm.lu

Certain data related to the user's hardware and software that does not identify them are collected during their visit to the site. This collection is solely for the purpose of generating traffic statistics (browser type, resolution, approximate location, etc.) to better serve users.

The data controller for this processing is The Loupe.

The user's full IP address is never stored.

This data is stored in a solution provided by a subcontractor, who, as a subcontractor, is bound by the same legal obligations regarding personal data protection in case such data were to be collected in the future.

The retention period for the data does not exceed the time necessary to observe audience trends based on the evolution of browsers, resolutions used, or other available statistical data.

Presence on Social Media

Moderation Policy

Any user who joins the stemm.lu community on social media commits to disregarding all forms of discrimination based on race, color, religion, gender, sexual orientation, age, national origin, disability, or marital status.

Harmful, racist, sexist, or offensive comments have no place on social media. They will be deleted and reported.

The Facebook, Twitter, YouTube, and LinkedIn applications of www.stemm.lu are randomly monitored, and page management is not continuous.

Languages

On social media, stemm.lu communicates primarily in French. Depending on the situation and target audience, information may also be shared in the other two national languages or in English.

As far as possible, questions/comments will be answered in the user's language.