The European General Data Protection Regulation 2016/679 of 27 April 2016 (hereinafter referred to as the “GDPR Regulation”) protects the privacy and rights of individuals, which is a protection that is particularly important to us at Let’z Friends (as defined below).

This explanation note (hereinafter referred to as the “Note”) is designed to lay down the conditions in which Letz Friends, a simplified private limited liability company (société à responsabilité limitée simplifiée) incorporated and existing under the laws of the Grand Duchy of Luxembourg, having its registered office at 3, rue du Haut-Ruisseau, L-6446 Echternach, Grand Duchy of Luxembourg and registered with the Luxembourg Trade and Companies Register under number B294052 (“Let’z Friends”) processes personal data of its customers, members and persons showing an interest in its activities, where appropriate, in its capacity as controller, during your contractual relationship with it in accordance with the GDPR Regulation.

1. What types of personal data are processed?

The term “personal data” means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person (hereinafter referred to as the “Personal Data”).

Let’z Friends processes different categories of Personal Data:

• Personal Data enabling us to identify you and, among other things, to get in contact with you (for example: surname, first name, address, date of birth, nationality, telephone number, e-mail address, where necessary);
• Personal Data relating to your image, enabling us, on the basis of your express consent given in advance of an event, to film and/or record you and to use those data in the context of our (social) media presence. You will be notified of the precise purpose at the time when your consent is requested; and
• Personal Data relating to the event tickets and/or services you have purchased from us.

With a view to respecting the principle of data minimization as foreseen in point c) of Article 5 (1) of the GDPR Regulation, Personal Data are only collected, processed and kept if they are relevant and necessary for the performance of our services.

2. On what basis, and why, are your Personal Data used?

We may only process your Personal Data if there is a legal basis for such processing, in accordance with Article 6 of the GDPR Regulation. We rely on the following principles:

• Personal Data that is required for the conclusion and performance of the contractual relationship (including the subscription to the membership) between you and Let’z Friends is based on point b) of Article 6(1) of the GDPR Regulation: “processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract”;
• Any additional Personal Data that you may voluntarily insert in your member profile, such as your interests, your hobbies or the languages you speak, are for the sole purpose of creating a profile about you to help you find members with similar interests and to suggest events that may be of interest to you. This processing is based on point (a) of Article 6(1) of the RGPD Regulation: “the data subject has given consent to the processing of his or her personal data for one or more specific purposes”; and
• When it comes to our marketing and sales activities for our own products and services, the legal basis is point (a) of Article 6(1) of the RGPD Regulation: “the data subject has given consent to the processing of his or her personal data for one or more specific purposes”. We always offer the right to object to this by giving the opportunity to unsubscribe during the subscription process, purchase of a ticket for an event, at any time via your member profile, and our unsubscribe links in our communications.

The Personal Data that you entrust to us enable us:

• to manage and deliver our services;
• to manage our contractual relationship with our customers and members;
• to inform our customers, members and persons showing an interest in our activities about new services, events or developments which may be useful to them ;
• to keep persons who have indicated their interest therein, by express consent (e.g. by signing up to receive our newsletter), informed of our activities and of our new services or developments,
• to transmit the requisite information to those administrative authorities that are entitled by law to receive it, such as the tax authorities.

3. Who has access to your data?

Your Personal Data are used by persons employed in Let’z Friends and the Let’z Friends’ management body.

Your Data are also transmitted to the following addressees in the context of the performance of their contract with Let’z Friends:

• our subcontractors (such as third-party suppliers, staff in charge of controlling event tickets, IT hosting platforms, etc.)
• our other service providers used to enable our business to function smoothly (providers of IT services, printing services, insurance companies).

In accordance with the contractual provisions and the applicable data protection legislation, Let’z Friend’s  partners and subcontractors undertake to process the Personal Data solely for the purposes of performance of their contractual obligations vis-à-vis Let’z Friends and to take the requisite measures to ensure that the confidentiality of those Personal Data is respected by their staff.

4. For how long are the Personal Data kept?

Whether you are a customer, member or a supplier, your Personal Data will be kept throughout the duration of our contractual relationship, and, after it comes to an end, for the period necessary for the performance of our legal and/or contractual obligations, or, where the processing was based on your consent (given e.g. at the time of requesting information about our services or membership), until such time as you request us to cease processing them.

Personal Data received during the time you have subscribed to a membership at Let’z Friends will be stored during two (2) years.

5. What are your rights?

The GDPR Regulation provides, within the limits prescribed by the applicable legislation, that you are entitled, as a “data subject”, free of charge:

• to demand access to your Personal Data;
• to demand rectification or erasure of your Personal Data;
• to demand restriction of processing of the Personal Data;
• to object to use of the Personal Data for marketing purposes;
• to demand the portability of your Personal Data.
• where the processing is based on point (a) of Article 6(1) or point (a) of Article 9(2) of the GDPR Regulation, the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

These rights may be exercised by sent to the following address: [email protected]. Let’z Friends reserves the right to request you to complete a specially dedicated form and provide it with a scanned version/paper copy of your identity card, so that we may verify your identity before dealing with your request.

You also have the right, in the event of any doubt concerning compliance by Let’z Friends with the applicable data protection rules, to lodge a complaint with a supervisory authority such as the National Data Protection Commission (Commission Nationale pour la Protection des Données – CNPD), having its offices at 15 Boulevard du Jazz, L-4370 Belvaux, Grand Duchy of Luxembourg.

6. Protection against fraudulent requests for personal data

Let’z Friends points out that no request for personal data will be made by telephone, whatever the purpose. Any solicitation claiming to come from Let’z Friends in this context must be considered fraudulent.

We invite our customers and partners not to respond to such requests and to report any suspicious incidents to the following address: [email protected].

This measure is intended to strengthen the security and confidentiality of the data you entrust to us, in accordance with the provisions of the GDPR Regulation.

7. How to contact us?

For any questions or requests regarding your Personal Data and its protection, all you need to do is send an email to [email protected].