Privacy Policy

General
The following is an overview of what happens to your personal information when you visit our website. (“Personal information” is any data with which you could be personally identified.) Detailed information on the subject of data protection can be found in our privacy policy found below.

Data collection on our website
Who is responsible for the data collection on this website?The processing of data on this website is carried out by VitalBriefing S.A. Contact details can be found in the required legal notice on this website.

How do we collect your data?
Some data is collected when you provide it to us. For example, this could be data you enter on a contact form. Other data is automatically collected by our IT systems when you visit the website. This primarily includes data that is technical in nature (e.g. internet browser, operating system or time a page is accessed). This data is collected automatically as soon as you enter our website.

What do we use your data for?
In part, the data is collected to ensure error-free provision of the website and to improve upon any issues that may exist. Other data may be used to analyse user behaviour on our site.

What rights do you have regarding your data?
At any time and free of charge, you have the right to request information about your stored data, its origin, its recipients and the purpose of its collection. You also have the right to demand the correction or deletion of this data, or request for its use to be restricted. For this purpose, as well as for further questions regarding data protection, you can contact us at any time using the address given in the site legal notice. You also have a right of appeal or to register a complaint with the relevant supervisory authority.

Analytics and third-party tools
When you visit our website, statistical analyses may be conducted of your surfing behaviour. This is done primarily through the use of cookies and with analysis programmes. The analysis of your surfing behaviour is generally anonymous, meaning that we cannot identify you from this data. You can object to this analysis or prevent it by not using certain tools. You will find detailed information on this in the following privacy policy.

You can object to this analysis. We will inform you below about how to exercise your options in this regard.


General information and mandatory information

Data protection
The operators of this website take the protection of your personal data very seriously. Your data is handled with absolute confidentiality and in strict accordance to the legal data protection regulations as well as this privacy policy.

If you use this website, various types of personal data are collected. Personal data counts as any data with which you could be personally identified. This privacy policy explains what information we collect and what we use it for. It also explains how we do this and for what purpose.

Please be aware that data over the internet (e.g. communication via e-mail) may be subject to security vulnerabilities and breaches. It is not possible to completely protect your data from access by third parties.

Notice concerning the party responsible for this website (i.e. the data controller)
The party responsible (controller) for processing data on this website is:

VitalBriefing S.A.
43, avenue Gaston Diderich
L-1420
Luxembourg, Luxembourg
Telephone: +352 28 48 74 37
E-mail: ops@vitalbriefing.com

The responsible party (controller) is the natural or legal person who, alone or jointly with others, decides on the purposes and means of processing personal data (e.g. names, e-mail addresses, etc.).

Withdrawal of your consent to the processing of your data
Many data processing operations are only possible with your express consent. You can revoke your consent previously given at any time. To do so, an informal e-mail sent to us making this request is sufficient. Please note that the data processing that takes place before we receive a request is still processed and is unaffected by the withdrawal.

Right to file complaints or appeal with the responsible regulatory authorities
Should a violation of data protection laws occur, the individual affected has a right to appeal to the competent supervisory authority. The competent supervisory authority in data protection matters is the National Commission for Data Protection in Luxembourg: https://cnpd.public.lu/en.html.

Right to data portability
You have the right to have data which we process based on your consent or in fulfilment of a contract automatically handed over to you or to a third party in a common, machine-readable format. If you request the direct transfer of the data to another controller, this will only be done to the extent technically feasible.

SSL or TLS encryption
This site uses SSL or TLS encryption for security reasons and for the protection of the transmission of confidential content, such as the inquiries you send to us as the site operator. You can recognize an encrypted connection in your browser’s address line when it changes from “http://” to “https://” and the lock icon is displayed in your browser’s address bar. If SSL or TLS encryption is activated, the data you transmit to cannot be read by third parties.

Information, blocking, deletion
As permitted by law within the framework of the applicable legal provisions, you have the right to obtain information free of charge at any time about your stored personal data, its origin and recipients, and the purpose of the data processing. If applicable, you also have the right to have this data corrected, blocked or deleted. For this purpose, as well as for further questions regarding personal data, you can contact us at any time using the address given in the site legal notice.

Opposition to promotional e-mails
We hereby expressly and resolutely object to the use of the contact data published as part of our obligation to publish a site notice for the transmission of advertising, promotional and informational materials not expressly requested. The website operator expressly reserves the right to take specific legal action if unsolicited advertising material, such as spam e-mails, is received.


Data protection officer

Statutorily required data protection officer
We have appointed a data protection officer for our company.

VitalBriefing S.A.
Mr. Cormac Bracken
43, avenue Gaston Diderich
L-1420
Luxembourg, Luxembourg

Phone: +352 28 48 74 37
E-mail: cbracken@vitalbriefing.com


Data collection on our website

Cookies
Some of our web pages use cookies. Cookies do not harm your computer nor do they contain any viruses. Cookies are used to help make our website more user-friendly, efficient, effective and secure. Cookies are small text files that are stored on your computer and saved by your browser.

Most of the cookies we use are known as “session cookies.” These files are automatically deleted at the end of your visit to the site. Other cookies remain stored on your end-device’s memory until you delete them. These cookies enable us to recognise your browser upon your next visit to our site.

You can configure your browser to inform you about the use of cookies in order to decide for yourself on a case-by-case basis whether to accept or reject a cookie. Alternatively, your browser can be configured to accept cookies automatically under specific conditions, to always reject them and to delete cookies automatically when the browser is closed. If you disable the use of cookies, the functionality of this website may be limited.

Cookies required to carry out the electronic communication process or to provide certain functions you wish to use (e.g. subscription forms) are stored pursuant to Art 6 (1) (f) of GDPR. The website operator has a legitimate interest in the storage of cookies to ensure an optimised service provided free of technical errors. If other cookies (e.g. those used to analyse your surfing behaviour) are stored, they will be treated separately in this privacy policy.

Contact form
Should you send us inquiries via the contact form, we will collect the data entered on the form, including the contact details you provide, for the purpose of processing the inquiry, answering your questions and in the event of any follow-up questions. This data will not be shared without your consent.

The processing of the data you enter onto the contact form is therefore exclusively based on your consent — Art. 6 (1)(a) GDPR. You may withdraw consent at any time. An informal e-mail making this request is sufficient. Please note that the data processing that takes place before we receive a request is still processed and is unaffected by the withdrawal.

The data you enter in the contact form will be retained by us until you request for it to be deleted, withdraw your consent for its storage, or the purpose for which the data was stored no longer applies (e.g. after your request has been processed). Any mandatory legal provisions, particularly those regarding mandatory data retention periods, remain unaffected by this provision.


Analytics tools and advertising

Google Analytics
This website uses Google Analytics, a web analytics service that is operated by Google Inc., 1600 Amphtheatre Parway, Mountain View, CA 943043, USA.

Google Analytics uses so-called ‘cookies.; These are text files that are stored on your computer and enable an analysis of the use of the website by you. The information generated by the cookie about your use of this website is usually transmitted to a Google server in the USA and stored there.

The storage of Google Analytics cookies is based on Art. 6 (1) (f) GDPR. The website operator has a legitimate interest in the analysis of user behaviour in order to improve and optimise both its website and its advertising.

IP anonymisation
We have activated the IP anonymization feature on this website. Your IP address will be shortened by Google within the European Union or other parties to the Agreement on the European Economic Area prior to transmission to the United States. Only in exceptional cases is the full IP address sent to a Google server in the US and shortened there. Google will use this information on behalf of the operator of this website to evaluate your use of the website, to compile reports on website activity, and to provide other services regarding website activity and Internet usage for the website operator. The IP address transmitted by your browser as part of Google Analytics will not be merged with any other data held by Google.

Browser Plugin
You can prevent these cookies being stored by selecting the appropriate settings in your browser. However, we wish to point out that doing so may mean you will not be able to enjoy the full functionality of this website. You can also prevent the data generated by cookies about your use of the website (including your IP address) from being passed to Google, and the processing of these data by Google, by downloading and installing the browser plugin available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en.

Objecting/opting out of data collection
You can prevent the collection of your data by Google Analytics by clicking on the following link. An opt-out cookie will be set to prevent the collection of your information during future visits to this website: Disabling Google Analytics.

For more information on how Google Analytics handles user data, please see the Google privacy policy: https://support.google.com/analytics/answer/6004245?hl=de.

Demographic data collection by Google Analytics
This website uses Google Analytics’ demographic features. This allows reports to be generated containing statements about the age, gender, and interests of site visitors. This data comes from interest-based advertising from Google and third-party visitor data. This collected data cannot be attributed to any specific individual person. You can disable this feature at any time by adjusting the ads settings in your Google account or you can forbid the collection of your data by Google Analytics as described in the section “Refusal of data collection”.


Google reCAPTCHA

We use “Google reCAPTCHA” (hereinafter “reCAPTCHA”) across our website. This service is provided by Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA (“Google”).

reCAPTCHA is used to check whether the data entered on our website (such as on a contact form) has been entered by a human or by an automated programme. To do this, reCAPTCHA analyses the behaviour of the website visitor based on various characteristics. This analysis starts automatically as soon as the website visitor enters the website. For the analysis, reCAPTCHA evaluates various information (e.g. IP address, how long the visitor has been on the website, or mouse movements made by the user). The data collected during the analysis will be forwarded to Google.

The reCAPTCHA algorithm checks to see if there is a Google cookie placed on the computer being used. An additional reCAPTCHA-specific cookie will then be added to the user’s browser allowing a complete snapshot of the user’s browser window at that moment in time. The data collected during the analysis will be forwarded to Google.

Information gathered includes:

  • All cookies placed by Google over the last 6 months
  • How many mouse clicks you’ve made on that screen (or touches on a touch device)
  • The CSS information for that page
  • The date
  • The language your browser is set to
  • Any plugins you have installed on the browser
  • All Javascript objects

.

The reCAPTCHA analyses take place completely in the background. Website visitors are not advised that such an analysis is taking place.

Data processing is based on Art. 6 (1) (f) DSGVO. The website operator has a legitimate interest in protecting its site from abusive automated crawling and spam.

For more information about Google reCAPTCHA and Google’s privacy policy, please Google’s terms and privacy documents.


Newsletter

Newsletter data
If you would like to receive one of our newsletters – referred to on our website as Briefings – we require a valid e-mail address as well as information that allows us to verify that you are the owner of the specified e-mail address and that you agree to receive this newsletter. No additional data is collected or is only collected on a voluntary basis. We only use this data to send the requested information and do not pass it on to third parties.

We will, therefore, process any data you enter onto the contact form only with your consent per Art. 6 (1) (a) GDPR. You can revoke consent to the storage of your data and e-mail address as well as their use for sending the newsletter at any time, e.g. through the “unsubscribe” link in the newsletter. The data processed before we receive your request may still be legally processed.

The data provided when registering for the newsletter will be used to distribute the newsletter until you cancel your subscription, at which time said data will be deleted. Data we have stored for other purposes (e.g. email addresses for the members area) remain unaffected.


Mailchimp
This website uses the services of MailChimp to send newsletters (Briefings). This service is provided by Rocket Science Group LLC, 675 Ponce De Leon Ave NE, Suite 5000, Atlanta, GA 30308, USA.

MailChimp is a service which organizes and analyses the distribution of newsletters. If you provide data (e.g. your e-mail address) to subscribe to one of our Briefings, it will be stored on MailChimp servers in the US.

MailChimp is certified under the EU-US Privacy Shield. The Privacy Shield is an agreement between the European Union (EU) and the US to ensure compliance with European privacy standards in the United States.

We use MailChimp to analyse our Briefing campaigns. When you open an email sent by MailChimp, a file included in the e-mail (called a web beacon) connects to MailChimp’s servers in the United States. This allows us to determine if a newsletter message has been opened and which links have been clicked by recipients. In addition, technical information is collected (e.g. time of retrieval, IP address, browser type, and operating system). This information cannot be assigned to a specific recipient. It is used exclusively for the statistical analysis of our newsletter campaigns. The results of these analyses can be used to better tailor future Briefings to your interests.

If you do not want your usage of the newsletter to be analysed by MailChimp, you will have to unsubscribe from the newsletter. For this purpose, we provide an unsubscribe link in every newsletter we send.

Data processing is based on Art. 6 (1) (a) GDPR. You may revoke your consent at any time by unsubscribing to the newsletter. The data processed before we receive your request may still be legally processed.

The data provided when registering for the newsletter will be used to distribute the newsletter until you cancel your subscription, at which time said data will be deleted from our servers and those of MailChimp. Data we have stored for other purposes (e.g. e-mail addresses for the members area) remains unaffected.

For details, see the MailChimp privacy policy at https://mailchimp.com/legal/terms/.

Completion of a data processing agreement:

We have entered into a data processing agreement with MailChimp, in which we require MailChimp to protect the data of our customers and not to disclose said data to third parties. This agreement may be viewed at the following link: https://mailchimp.com/legal/data-processing-addendum/