Privacy notice related to donors or potential donors
Introduction
In accordance with transparency obligations of the EU Regulation 2016/679 General Data Protection Regulation (hereafter the “GDPR”), this Privacy Notice (hereafter “the Notice”) explains how the University of Luxembourg processes personal data in relation to you as donor or potential donor.
In addition to the information in this Notice, you may be given further information about the uses of your personal data for specific activities at the University.
Who are we?
The University of Luxembourg is a public higher education and research establishment, operating under the supervision of the Ministry for higher education.
The University of Luxembourg has its official address at:
Maison du Savoir
2, place de l’Université
L- 4365 Esch-Belval
Phone number: Tel.: (+352) 46 66 44 1
Internet address: https://www.uni.lu/
The University has appointed a DPO: reachable during working hours.
Further information is provided on:
Why does the University process your personal data and on which legal basis?
Overall, the University will use your personal data to manage your relationship with us as a University donor or potential donor. The main purposes of our processing activities, and their corresponding legal bases, are the following:
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Purpose
Collect and manage your donation
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Categories of personal data
• First and last name
• Contact details (postal address, email address, phone number)
• The donation amount and cause -
Legal basis
For all personal data
Performance of a contract
The processing of your personal data is necessary for the performance of the donation contract we have entered with you as a University donor (Article 6 para. 1 (b) GDPR).
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Purpose
Provide you with a thank you letter also serving as a tax certificate relating to the payment of your donation.
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Categories of personal data
• First and last name
• Contact details (postal address, email address, phone number) -
Legal basis
For all personal data
Compliance with a legal obligation
The processing of your personal data may also be necessary for compliance with our legal obligations under Article 6 para. 1 (c) GDPR.
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Purpose
Obituary donations: Transmit your contact details at the request of a third party (in particular the family of a person whose obituary note motivated your donation)
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Categories of personal data
• First and last name
• Contact details (postal address, email address, phone number)
• Electronic address if provided by you -
Legal basis
For all personal data
Legitimate interests
The processing is necessary for the legitimate interest of a third party (Article 6 para. 1 (f) GDPR) as they can thank you directly as it is the custom.
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Purpose
Donor stewardship (keeping the donors informed with newsletters, regular updates about their field of interest…)
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Categories of personal data
• First and last name
• Contact details (postal address, email address, phone number)
• Electronic address if provided by you
• Phone if provided
• Professional affiliation
• Areas of interest -
Legal basis
For all personal data
Legitimate interests
The processing is necessary for the legitimate interest of the University and the donor (Article 6 para. 1 (f) GDPR) to provide you with details about the progress of projects you financed and inform you about new opportunities.
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Purpose
Prospect research: For the management of our relationship with potential donors
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Categories of personal data
• First and last name
• Areas of interest
• Public information on social network or any other support e.g newspaper. -
Legal basis
For all personal data
Legitimate interests
The processing is necessary for the legitimate interest of the controller (Article 6 para. 1 (f) GDPR) as the University has an interest to develop relationship with potential donors to inform them about the research activities of the University and the opportunities to become donor. The processing is also necessary of the legitimate interest of the controller (Article 6 para. 1 (f) GDPR) as the University needs to do their due diligence on the donor to decide whether the University is willing to entire a philanthropic partnership with this donor.
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Purpose
For the management of our website. We process personal data with every visit to our website.
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Categories of personal data
• IP address
• Browsing statistics -
Legal basis
For all personal data
Legitimate interests
The processing is necessary for our legitimate interest (Article 6 para. 1 (f) GDPR) (i.e providing access to and protecting our website). The information notice regarding the processing in relation with the University website is detailed on the University website.
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Purpose
The University organises numerous events and may take photographs or videos. The University may further disseminate the material taken during events for promotional purposes.
You will be notified before the event if the University intends to film and/or take photographs and/or onsite. If you do not wish to be photographed or filmed, please contact the organisers of the event.
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Categories of personal data
• Image (photo and video) and associated promotional material
• Audio (audio recordings) -
Legal basis
For all personal data
Legitimate interests
Depending on the circumstances under which the photographs or videos are taken, the legal basis of this processing activity is the legitimate interests of the University under Article 6 para. 1 (f) GDPR (i.e. internal or external communication).Consent
In other cases, consent will be requested for taking and publishing photos or video recordings.
The University collects the vast majority of the information directly from you. Some information is collected from public sources.
The University does not carry out automated decision-making for the above-mentioned purposes.
FAQ
Your personal data is collected as part of our relationship management with current and potential future donors:
5.1. Internal recipients
a) The fundraising office;
b) Any other departments of the University on the basis of the need to know principle e.g accounting or Legal department;
c) any other department of the Faculties or Interdisciplinary Research Centers of the University being in contact with the University donors or potential donors.
The internal communication from the fundraising office to the other entities or departments of the University is strictly limited to what is necessary.
5.2. External recipients
a) The Company SFDC Ireland Limited, having its registered office at 1 Central Park, Leopardstown, Dublin 18, Ireland who is providing the Customer Relationship Management Platform called Salesforce as processor in the meaning of the GDPR.
The University and SFDC Ireland concluded a data processing agreement due to the processor qualify of this service provider.
More generally, all third-party service providers that process data on our behalf are required to take appropriate security measures to protect your data in line with our policies. We do not allow them to use your data for their own purposes. We permit them to process your data only for specified purposes and in accordance with our instructions.
Your Personal Data is mainly processed within the European Union for the different purposes listed in section 2. There are situations when we transfer your data outside of the European Economic Area as our Service Provider of Salesforce (as mentioned in section 5.2) use subcontractors or operates within group entities located outside of the European Union. Appropriate safeguards have been put in place by the University including the conclusion of agreements annexing the standard contractual clauses approved by the European Commission for such transfers and the service provider has implemented Binding Corporate Rules at Group level. For further information on the measures in place, please contact the Data Protection Office.
The University will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for.The retention periods we have defined depend on the purposes of our processing activities.
In particular, the personal data of University donors in relation with your donation agreement will be kept for the time necessary to achieve the purpose and comply with our obligations in tax and accounting matters (10 years from the moment of signature).). The donors’ personal data collected to ensure continued stewardship (newsletter,annual reports etc) will be stored as long as you do not object to the processing.
The retention period is relation with the events is detailed in our dedicated privacy noticy published on the University website and available on Privacy notice related to events management.
The future potential donors’ personal data will be stored as long as you do not object to the processing.
According to the GDPR, you benefit notably from the following rights: right to be informed, right to access to your personal data, right to rectification, right to erasure, right to restrict the scope of the processing, right to object, right to data portability, right to lodge a complaint.
- Right to be informed: you have the right to know how your personal data is collected and used.
- Right to access you have the right to obtain a copy of the personal data we hold about you and to check whether it is lawfully processed.
- Right to rectification: you have the right to request the University to rectify any inaccurate personal data we hold about you.
- Right to erasure: you have the right to obtain from us the erasure of personal data concerning you without undue delay. This right will only apply where, for example, you consider that there is no good reason for us continuing to process it and your personal data are not necessary for us; or where you withdraw your consent if we are using your personal data based on your consent; or where you object to the way we process your data (in line with the Right to object mentioned below).. Note, however, that we may not always be able to comply with your request of erasure for specifical legal reasons which will be notified to you, if applicable at the time of your request.
- Right to restrict the processing: you have the right to suspend the processing of your personal data under certain circumstances (for instance if you want us to establish its accuracy or the reason for processing it).
- Right to object: you have the right to object on grounds relating to your situation, based on points (e) or (f) of Article 6 (1) GDPR.
- Right to data portability: in the instances where the processing is based on your consent and is carried out by automated means, you have the right to receive your personal data and to request the transmission of your data to another party.
- Right to withdraw consent: in the instances where you have consented to the processing, you can withdraw your consent at any time by contacting the relevant department.
The University provides further information on its website page to the exercise of rights section.
In practice, you can exercise your rights by contacting directly the DPO, the contact details is dpo@uni.lu.
Any request shall be processed by the University without undue delay, and where feasible no later than one (1) month after its receipt, at least in order to inform you about the status of your request. This period may be extended for two (2) additional months for complex cases or due to a high volume of requests. Please note that we may keep a record of your communications to help us resolve any issues which you raise.
If you remain unsatisfied, you have the right – without prejudice to any other administrative or judicial remedy – to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement.
In Luxembourg, the competent authority is the Commission Nationale pour la Protection des Données (CNPD).
Contact of the CNPD:
Commission Nationale pour la Protection des Données
Service des réclamations
15, Boulevard du Jazz
L-4370 Esch-sur-Alzette
Tel. : (+352) 26 10 60 -1
Fax : (+352) 26 10 60 -29
You can also use their contact form.
Changes to this Notice
Any changes we make to this Notice in the future will be posted on the University’s website and, where appropriate, notified to you by e-mail.
Last update: on 26 August 2024.