Privacy Policy and Cookies

Data protection statement

In our data protection statement, you will find detailed information about the processing of your personal data by The National Language Institute Luxembourg.

WHO ARE WE?

The National Institute for Languages Luxembourg (hereafter “INLL“) is a Luxembourgish public administration under the authority of the Minister of Education, Children and Youth.

Our missions
As a language learning centre, the INLL:

provides foreign language courses for adults to:
- Promote multilingualism
- Facilitate integration and social cohesion
- Contribute to employability
promotes intercultural exchange through the practice of the languages taught
offers literacy and numeracy courses

As a national certification centre, the INLL:

Certifies knowledge of the Luxembourgish language for regulated diplomas and certificates in Luxembourgish
Organises international tests and examinations in foreign languages

Contact

21 Bd de la Foire, L-1528 Luxembourg
(+352) 26 44 30 1
Contact form
https://www.inll.lu/

Why do we process your personal data?

LLO.LU offers users Luxembourgish language course services accessible from:

The online learning platform https://www.llo.lu/
The LLO.LU mobile application (iOS app: [https://apps.apple.com/us/app/llo/id1628802290 / Android app: [https://play.google.com/store/apps/details?id=com.altissia.llo_lu]

Access to these language courses requires the processing of personal data, i.e., data that can identify you as an individual.

The data collected by LLO.LU in the context of a study on language knowledge (in particular to refine the test offered to users) is anonymised and is intended solely to produce anonymous overall statistics that do not allow users to be identified. Therefore, such processing does not fall within the scope of this data protection statement.

The services are performed by ALTISSIA INTERNATIONAL S.A. (“Altissia“). In this context, Altissia processes your personal data on behalf of and following instruction by the INLL, which remains solely responsible for processing your personal data.

In addition, as part of the performance of the services, we may subcontract (and authorise Altissia to subcontract), in whole or in part, certain tasks to technical subcontractors, for example, to host the website and store data and back-up copies with an IT company.

In all cases, we ensure that these processors handle your data, just as we do, in a secure, respectful, and responsible manner, and we provide adequate contractual guarantees to this effect. LLO.LU, therefore, requires its processors to comply with data protection legislation and provide sufficient guarantees that appropriate technical and organisational measures have been implemented, so that the processing meets the requirements of the applicable data protection legislation and guarantees the protection of your rights.

We do not intentionally collect personal information from children under the age of 16 without the express permission of a parent or guardian. If we discover that we have inadvertently collected information from children under the age of 16, we will take steps to delete the data as soon as possible, unless we are required by the applicable law to retain it.

What personal data processing do we carry out?

Below you will find information on the data processing we carry out, the legal basis and reasons for such processing, the categories of personal data processed, how we collect this data, the period for which we retain it, and the possible recipients of the personal data.

Information security: registering of visitors when they visit the site, the application, or the llo.lu platform

Purposes	We process this personal data to ensure (information) security and the proper functioning of llo.lu when you consult the website, the application, or the platform.
Legal basis	The processing of your data is necessary for the pursuit of our legitimate interests in ensuring the security of information and the proper functioning of llo.lu.
Personal data	Identification data and data related to the visit: · IP address · Date and time of access to the site · Browser type used · Platform and/or operating system installed on the device (computer, tablet, smartphone)
Collection	Data is collected directly from the user upon each visit.
Storage duration	2 years
Recipients	Google Kubernetes

Creation of a personal account in order to use the services

Purposes	We process your personal data to enable the use of the services via the website, the application, or the llo.lu platform.
Legal basis	To use our services, you must first create a personal account. The processing of your data in this context is necessary for the execution of the service contract that you conclude with LLO.LU when you create a personal account and accept the terms of use of llo.lu.
Personal data	The following personal data must be entered when creating a personal account: · Surname · First name · Date of birth · Gender · Post code · Country of residence · Nationality
Collection	The data is collected directly from the user when the personal account is created.
Storage duration	This data is stored during the entire time the account is active and for a period of 2 years after the account is closed or inactive.
Recipients	Altissia, INLL

Provision of language course services

Purposes	We process your personal data to provide you with the Luxembourgish language courses you have enrolled in, personalise them, and refine the learning methods.
Legal basis	The processing of your data is necessary for the performance of the service contract you conclude with INLL for the use of LLO.LU.
Personal data	The following personal data are processed for the provision of the service: identification data (first name, surname, gender, post code, country of residence, nationality), contact data (email address), language level, test results, and learning preferences.
Collection	Data is collected directly from the user. Some data such as activity results or assessments are generated by teachers when using LLO.LU.
Storage duration	This data is stored for as long as the account is active and for a period of 2 years after the account is closed or inactive.
Recipients	Altissia, INLL

Technical support

Purposes	We process your personal data to provide you with the technical support necessary for the proper use of LLO.LU.
Legal basis	The processing of personal data relating to technical support is necessary for the execution of the service contract you conclude with LLO.LU for the use of LLO.LU.
Personal data	Email address
Collection	The data is collected directly from the user for each support request.
Storage duration	2 years
Recipients	Altissia, Zendesk, INLL

Processing of requests relating to the processing of personal data

Purposes	We process your personal data to process and respond to your requests.
Legal basis	The processing of your data is necessary to comply with our legal obligations as data controller to process and respond to your requests, under Articles 12 and 15 to 22 of the General Data Protection Regulation.
Personal data	Your first name, surname, email address, post code, country of residence, nationality, date of birth, and the content of your request.
Collection	The data is collected directly from you.
Storage duration	We keep your data for 5 years after the file is closed.
Recipients	INLL and its legal advisors, if any.

Will my personal data be transferred to countries outside the European Economic Area?

The European Economic Area (“EEA”) includes the countries of the European Union as well as Norway, Liechtenstein, and Iceland. Applicable data protection law requires additional safeguards if INLL and/or its processors transfer your personal data to countries outside the EEA.

Some third parties we use to perform the services process your personal data in countries outside the EEA.

These transfers will only take place in accordance with the applicable law. Additional safeguards taken by LLO.LU include entering into agreements based on the European Commission’s model provisions.

You can contact us at any time to obtain a full overview of the appropriate safeguards.

What cookies do we use?

The cookies we use on our site and app are described in more detail in our [link to cookie policy].

We would also like to point out that our site may contain links to third-party websites, and some of our services also give you access to third-party services (such as the social networks Facebook and YouTube). We have no control over how third-party sites and services process your data. We encourage you to carefully read the data processing policies of any third-party websites you access from our site.

What are your rights and how can you exercise them?

If and insofar as provided for by the applicable Luxembourgish and European regulations, you have the following rights:

Access	You have the right to obtain confirmation as to whether LLO.LU is processing your personal data and, if so, you may access the personal data that LLO.LU is processing. We can provide you with a free copy, however this will not be possible for all documents because we must also respect the rights and freedoms of others.
Rectification	You have the right to request LLO.LU correct any inaccurate or incomplete personal data without undue delay.
Objection	If we process your personal data based on our legitimate interest: You have the right to object to the processing of your personal data (in which case there will be an assessment as to whether there are compelling legitimate grounds for the processing which outweigh your personal rights or interests) and the use of your personal data for direct marketing purposes.
Restriction of processing	You have the right to request we restrict the processing of your personal data, for example while we verify, at your request, the accuracy of your personal data.
Erasure	You have the right to request that LLO.LU delete your personal data. However, it is not possible in every case to delete all personal data, for example, if the processing of such data is necessary for the establishment, exercise, or defence of legal claims or if we are obliged by the legal authorities to retain such data. You can receive further information regarding this upon request.
Portability	If we process your personal data to enter into or perform a contract: You have the right to obtain your personal data in a structured, commonly used, and machine-readable format and to transfer this data to another controller or processor.
Withdrawal of consent	If we process your personal data with your consent: You have the right to withdraw this consent at any time. This can be done via an unsubscribe button in the newsletters or by following the procedure described below.

You can exercise these rights by sending an email to dpo@men.lu or by writing to us at the mailing address mentioned at the beginning of this statement.

Please ensure that it is always clear which right you wish to exercise and how you wish to receive the information (e.g., by email, post, verbally, etc.). In some cases, we may ask you for additional information, for example to confirm your identity.

If you contact us to exercise your rights, we will respond within one month. Exceptionally, this period may be longer (up to 3 months in total), but in this case, we will inform you within one month. Whether or not you can exercise your rights depends on the processing and the legal basis.

You have the right to lodge a complaint with the competent supervisory authority if the processing of your personal data violates the applicable regulations. In Luxembourg, the competent authority is the Commission nationale pour la protection des données, 15 Jazz Boulevard, L-4370 Belvaux, tel: (+352) 26 10 60 -1, https://cnpd.public.lu/fr/commission-nationale.html.

Changes to the privacy policy

LLO.LU may amend this data protection declaration, particularly in the event of legislative changes. You should always consult the latest version of the data protection declaration on our website https://www.llo.lu/. The date of the most recent version is indicated at the beginning of the document.

Cookie Policy

A cookie is a small text file that websites you visit save on your computer or mobile device. It allows these sites to remember your actions and preferences (such as username, language, font size, and other display settings) for a period of time so that you do not have to re-enter this information each time you visit these websites or navigate from one page to another.

The LLO.LU Site and Application (hereafter referred to as the “websites”) primarily use “third party cookies”. These are cookies defined and managed by the service provider, ALTISSIA International S.A., which acts on behalf of and under the direction of the person responsible for processing the INLL under the supervision of the Ministry of Education [1]. This type of cookie can only be read by our websites.

However, some pages on our websites may use external services, which also set their own cookies; these are called third-party cookies. For this reason, you will need to accept cookies from these external services to view some of our pages.

Our three types of third-party cookies enable us to:

Save visitor preferences
Ensure the proper functioning of our websites
Collect data for analysis (of user behaviour)

Visitor Preferences

These are defined by us and only we can read them.

Name	Service	Purpose	Type of cookie and storage duration
wpca_cc	LLO.LU public site	The “remember_web” cookie (also known as the “remember me” cookie) is generated by the Service when you log in to the platform. This cookie saves your credentials to allow you to log back in quickly when the session has expired. It is deleted when you log out.	Proprietary cookie, duration of 1 year
wpca_content	LLO.LU public site	This cookie contains the user’s identifier, which is used to “remember” the user in case their session expires between visits.	Proprietary cookie, duration of 1 year
Consent or plug-in banners

Operational Cookies

Some cookies need to be added to ensure that certain web pages function correctly; therefore, they do not require your consent. These cookies are:

Authentication cookies
Technical cookies required for certain computer systems

2.1 Authentication Cookies

These cookies are registered when you log in to the LLO.LU platform. By doing so, you agree to the associated privacy policy.

Name	Service	Purpose	Type of cookie and storage duration
JSESSIONID	LLO.LU	This cookie is used to access secure areas of the site (areas requiring authentication). It is used to maintain your login status on different pages.	Proprietary cookie, duration of session
_idp_*	LLO.LU	This cookie is used to access secure areas of the site (areas requiring authentication). It is used to maintain your login status on different pages.	Proprietary cookie, duration of session
_zendesk_session	Support Service	Register a unique session key for the Zendesk Classic application	Essential third-party cookie, duration of 1 year

2.2 Technical cookies

Name	Service	Purpose	Type of cookie and storage duration
NG_TRANSLATE_LANG_KEY	LLO.LU	This cookie is used to track the selected language.	Proprietary cookie, duration of session
__cfduid	Technical error analysis service and technical support	Cloudflare security settings for guide resources.	Third-party cookie, 1 month

Analytical Cookies

These cookies are used for internal research purposes only to improve the service we offer to our users.

These cookies analyse how you use our websites and are anonymised (the data collected does not identify you personally).

This data is not shared with third parties or used for other purposes.

Name	Service	Purpose	Type of cookie and storage duration
_pk_id#	Web analytics service for companies, based on the open-source software Matomo	Recognises website visitors (anonymously; no personal information is collected about the user).	Proprietary persistent cookie, 13 months
_pk_ses#	Web analytics service for companies, based on the open-source software Matomo	Identifies the pages a user views during a single visit (anonymously; no personal information is collected about the user).	Proprietary persistent cookie, 30 minutes
in-token	Technical error analysis service	Tracks user sessions.	Third-party cookie, 7 days
stg_traffic_source_priority	Web analysis service	Stores the type of traffic source showing how the visitor reached your website.	Proprietary cookie, 30 minutes
stg_returning_visitor	Web analysis service	Determines if this is a repeat visitor.	Proprietary cookie, 1 year
stg_last_interaction	Web analysis service	Determines if the visitor’s last session is still in progress or if a new session has started.	Proprietary cookie, 1 year
stg_externalReferrer	Web analysis service	Stores the URL of a website that referred a visitor to your website.	Proprietary cookie, session duration
Instata		Monitoring, tracking

You can only access the LLO.LU support service after giving your consent to enable third-party tracking cookies and web beacons. Your consent to access the support service is requested through a pop-up window when accessing the site. By clicking on the “Access Support” link, you agree to enable third-party cookies and web beacons.

To view this third-party content, you must first agree to their specific terms and conditions, including their cookie policy, over which we have no control.

If you do not view this content, no third-party cookies will be placed on your device.

How to Manage Cookies

You can manage and/or delete cookies as you wish. For more information, visit aboutcookies.org. You can delete cookies already stored on your computer and set most browsers to block them. However, if you do this, you may have to set certain preferences yourself each time you visit a site, and some services and features may not be available.
Implied Consent

Cookie options for the public area of the site only

BUTTONS on the site

“Do Not Track” Option

The “Do Not Track” feature allows visitors to opt out of being tracked on websites by analytics services, advertising platforms, or social networks. The following links explain how to activate the “Do Not Track” function in these browsers:

Piwik Pro respects the preferences of visitors and does not track those who have enabled “Do Not Track” in their browser. If the user does not have “Do Not Track” enabled and chooses not to be tracked, the “piwik_ignore” cookie is stored by the browser. Visitors with the “piwik_ignore” cookie are not tracked. If the visitor disables all cookies in their browser, they will continue to be tracked, but their data will be less accurate (Piwik cookies will not be used). If the visitor is using a browser with “Do Not Track” enabled by default (e.g., Internet Explorer 11), this feature is not taken into account.