Data Privacy Policy

This data privacy policy applies to all our members, contracting parties, prospective contracting parties, persons contacting the ABBL via its website or other communications means and their respective representatives, who deal with the ABBL and whose personal data (hereinafter “The/Your Data”) are processed by the ABBL (hereinafter referred to as the “Concerned Person” or the “Concerned Persons“).

In accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, and repealing the Directive 95/46 / EC, (hereinafter the “GDPR“), we wish to inform the Concerned Persons about the processing of their personal data.

The ABBL wishes to draw your attention to the fact that certain activities that involve the processing of Your Data are also subject to specific notices accessible via the forms or websites from which Your Data is collected.

1. Who is the controller for Your Data?

The Association des Banques et Banquiers, Luxembourg is established and has its registered office at 12, rue Erasme, L-1468 Luxembourg, registered with the Luxembourg Trade and Companies Register under number F352 (hereafter referred to as the “ABBL”) is the controller for Your Data.

In compliance with the GDPR, the ABBL can act both as a data controller and a processor.

2. Which Data is processed?

The ABBL is committed to observing the data minimisation principle and ensures that only appropriate and relevant data is processed as required for the purposes defined.

Based on the purpose of the processing, the ABBL mainly processes:

identification and contact data: name, greeting, address, telephone number, date of birth, nationality, passport number;
professional data: title, function, company, survey responses, position taken or vote cast at a meeting, membership, CVs;
data related to areas of interest: business topic; geographical region, product and service of the ABBL;
technical data: data collected during your visit to the ABBL website, page visited, IP address, type of browser, browser version used, ID code for participation in surveys;
data regarding your image and/or voice.

3. How is Your Data collected?

Your data will be collected upon the first contact with the ABBL, when the Concerned Persons complete forms or communicate, for example, by telephone or email with the ABBL, apply to become a member of the ABBL and otherwise in the context of the contractual relationship entered into between the Concerned Persons and the ABBL.

4. What are the legal basis used by the ABBL to process Your Data?

The primary legal basis for the processing of the Concerned Persons’ personal data is, on the one hand, the proper performance of the contractual or pre-contractual relationship with the Concerned Persons, and, on the other hand, the processing is necessary for the purposes of the legitimate interests pursued by the ABBL.

Another legal basis for the processing of the personal data of the Concerned Persons for specific purposes can be their consent (for example, in the context of establishing contact with the ABBL, or otherwise for marketing purposes). The consent can be withdrawn at any moment. If the processing is in parallel based on another legal basis, then the withdrawal of the consent will in principle not impact the processing by the ABBL (or at least not the full extent of the processing).

Another legal basis for the processing of the personal data of the Concerned Persons may also be the legal obligations applicable to the ABBL.

For certain processing, more than one legal basis may apply.

5. Why is Your Data being processed and what is the legal basis for such processing?

The ABBL processes Your Data for the following purposes:

Legal basis for the processing	Purpose of the processing	Who does it apply to?
Processing is required for the fulfilment of the ABBL’s contractual obligations.	Assist, share information with and support members Issue opinion and comments on proposed European and domestic legislation Lead thematic working groups and other task forces Organise events, assignments, representatives delegations and shared stands Establish contacts with institutional and non-institutional partners Compile statistics and conduct research and analysis (using surveys) Manage press enquiries Send out publications Manage the ABBL websites, blogs and social media accounts Organise training courses and webinars	Members (and where applicable, the contact person(s) of those entities) Beneficiaries of the services offered by ABBL, whether nationals or non-nationals (and where applicable, the contact person(s) of those entities) The contact person(s) in government bodies, federations, embassies and other institutional and non-institutional partners Speakers at events Anyone who wishes to receive one or more publications External experts Working group participants Candidates to job positions with ABBL members
Processing is required to ensure the ABBL’s compliance with one of its legal obligations.	Manage ABBL memberships and subscriptions as well as related issues Manage ABBL elections	Members (and where applicable, the contact person(s) of these entities) The contact person(s) in government bodies, federations, embassies and other institutional and non-institutional partners
Processing is required for the application of any agreements concluded with the ABBL that you are a party to, as well as the implementation of pre-contractual measures taken at your request.	Provide services as per the applicable agreements concluded with the ABBL Manage invoicing Provide rooms	Beneficiaries of the services offered by ABBL, whether nationals or non-nationals (and where applicable, the contact person (s) of those entities) Other parties to agreements with the ABBL and their contact persons
Processing is required for the ABBL’s legitimate interests in connection with the provision of services and the verification thereof.	Manage the quality of services offered by the ABBL and, in particular, conduct satisfaction surveys Transcription of a meeting for the purpose of drafting the minutes Adapt events to the interests and the membership status of the participants.	Beneficiaries of the services and events provided for or organised by the ABBL, whether nationals or non-nationals (and where applicable, the contact person(s) of those entities) Participants of ABBL meetings
Processing is carried out with your consent	Send out ABBL newsletters and correspondence Propose services and communication based on your interests Event-related correspondence that may use photographs or video Send out invitations and press releases, participate in press conferences Information-sharing during meetings	Anyone who has expressed a desire to receive the newsletter and/or other correspondence/invitations from the ABBL Participants and speakers at events and meetings of the ABBL

6. Who will have access to the Concerned Persons’ personal data?

Depending on the data concerned, the following positions within the ABBL will have access to and process the personal data in accordance with their respective responsibilities:

the persons responsible for data protection;
the secretariat; and
the IT department.

7. Who is Your Data transferred to?

Your Data is processed by duly authorised people within the ABBL, in accordance with their respective responsibilities.

For the aforementioned purposes, the ABBL may transfer Your Data to:

its institutional partners (other associations or federations, ministries, government bodies, embassies, trade organisations);
its non-institutional partners (businesses, training organisations, speakers, consultants, service providers) particularly when providing services to its members and jointly organising events, representatives’ delegations and shared stands; or
processors that process data on its behalf.

For the purposes of its international or other activities, the ABBL may transfer Your Data to international organisations or to countries located outside the European Economic Area:

subject to an adequacy decision made by the European Commission;
not subject to an adequacy decision made by the European Commission, in which case such transfers are subject to appropriate guarantees (such as the European Commission’s standard contractual clauses and additional measures where necessary), to ensure an adequate level of protection in all circumstances for the data transferred;
in the absence of an adequacy decision or appropriate guarantees, because the transfer is necessary for the conclusion or execution of an agreement concluded in your interests between the ABBL and another natural person or legal entity.

In any event, the ABBL shall ensure that such transfers are carried out in compliance with the applicable legal and regulatory provisions on data protection, including the GDPR.

8. What are your rights concerning Your Data?

You may exercise the following rights regarding Your Data:

the right to be duly informed of the use and processing of Your Data in accordance with the GDPR;
the right to access Your Data in accordance with the GDPR;
the right to rectify Your Data and to request the erasure of Your Data, provided that the legal constraints and obligations applicable to the ABBL do not conflict with such a request;
the right, in specific situations provided for under the GDPR, to obtain restriction of processing so that Your Data may only be processed with your consent (without prejudice to our right to store the data in accordance with data protection laws). The exercise of this right does not affect prior processing operations;
the right of the Concerned Person, in specific situations provided for under the GDPR, to receive all personal data concerning them which they have provided to the ABBL and to transmit those data to another data controller (right to data portability). The ABBL reserves the right to charge a fee for such transfer, in particular in the case of frequent requests and/or where the request is considered excessive in terms of the volume of data to be transferred. The Concerned Person shall inform the ABBL in writing, in due time prior to the termination of the contract, if they intend to exercise this right. Failing this, the ABBL cannot be held liable for the deletion of Your Data; and
the right, without prejudice to any other administrative or judicial remedy, to lodge a complaint with the Commission nationale pour la protection des données (CNPD) if the Concerned Person considers that they are subject to a breach in the processing of their personal data.

9. The right to unsubscribe/opt out

As the recipient of correspondence from the ABBL, you may choose to unsubscribe at any time by clicking on the dedicated link at the bottom of all publications and newsletters sent to you, or by sending an email to the ABBL in case such link is not available.

This will allow you to unsubscribe from the newsletter, all publications and/or publications on certain topics. The ABBL will then remove Your Data from the relevant distribution list(s).

However, please note that the ABBL may be required to keep Your Data in its databases if it processes such data for other purposes, as provided for under this Data Privacy Policy.

10. How is Your Data protected?

The ABBL undertakes to put in place the technical and organisational security measures required to protect Your Data.

11. How long is Your Data held for?

The ABBL holds Your Data no longer than necessary and in compliance with the purpose for which it has been collected and processed, without prejudice to the right of the ABBL to retain certain data for a longer period due to legal / regulatory obligations applying to the ABBL, respectively because of exceptional situations that would justify a longer storage (judicial procedure etc.).

The criteria used to determine this period are (i) the nature and sensitivity of the personal data and the purpose of its processing; (ii) the length of the statute of limitations for a right; (iii) general compliance with the law and regulations. More information can be provided via our contact details specified in paragraph 16 of this Data Privacy Policy.

The Data processed in order to send out publications and newsletters is held until you unsubscribe or until receipt of an error message regarding the mailbox used.

The ABBL holds data on traffic and operations on its website https://www.abbl.lu for a maximum of twelve months. Please refer to the Cookie Policy for details regarding cookies.

In principle, Your Data is deleted at the end of the storage period. However, some data is anonymised and held by the ABBL for use in statistics.

12. Events organised by the ABBL

When you sign up for an event in person, online (webinar) or in hybrid format that has been organised by the ABBL, you are informed and indicate your consent to the fact that:

you may appear in photographs and/or videos taken or recorded during the event; and
the event is likely to be recorded (sound and/or images) and broadcast, either live or after the event.

If you intend to oppose this processing of Your Data, we recommend that you indicate this prior to the event to the department responsible for its organisation, in order to find a means of preventing Your Data from being reproduced in photos and/or videos, to the extent that this is possible. If the event is held online, you will be offered the option of disabling your camera and/or microphone.

The purpose of taking and, where applicable, publishing/broadcasting photos and/or recordings of events is to provide information on events via the various communication channels used by the ABBL, such as websites, newsletters, social media (LinkedIn, …), video-sharing platforms (YouTube,…), etc.

In the context of events organised with partners, the ABBL may transfer photographs and/or recordings of the event to said partners. For further details, please refer to paragraph 7 of this Data Privacy Policy.

13. Meetings organised by the ABBL

When organising meetings held in person, online (videoconferences) or in hybrid format, the ABBL may process:

personal images in the form of photos; and/or
people’s image, voice and name, in recordings that may be broadcast live or after the meeting.

If you switch on or leave your camera and/or microphone switched on during a videoconference, you consent to the recording and subsequent broadcast of your image and/or voice in accordance with the terms described below.

The purpose of recording meetings is to make the recording available on a read-only basis to participants and those who were unable to attend the meeting, with the aim of facilitating information sharing.

In addition, subject to prior oral notification, a meeting held remotely (videoconferencing) or in a hybrid format may be automatically transcribed solely for the purpose of facilitating the drafting of the minutes of said meeting. In this respect, Your Data contained in the transcript will only be accessible to a limited number of employees of the ABBL and will be deleted once the minutes have been drafted.

14. ABBL Website

The ABBL is the data controller of the personal data collected through its website (the “Website”).

For browsing the Website, visitors are not required to disclose any personal data concerning them.

However, if a visitor requests publications or other information, or proactively completes a form available on the Website, the ABBL will collect identifiable personal data.

The personal data collected in this way may include information provided by the visitor, such as names, addresses, email addresses, telephone numbers, as well as any other identifiable personal information communicated by the visitor or indicated in any document submitted to the ABBL in this context.

Upon each visit to the Site, certain technical data (the “Technical Data”) are automatically recorded in a specific file on the Site’s server. The Technical Data may include, without limitation, the IP address, the Internet service provider, the operating system and browser type used by the visitor, the date and time of access to the Site, the page(s) visited, and the volume of data transferred.

The ABBL analyses the Technical Data for statistical purposes as well as for the management and improvement of the Website. The Technical Data collected will under no circumstances be used by the ABBL to profile visitors to the Website, so that the anonymity of each visitor is preserved. The Technical Data will not be transferred to third parties.

15. How is this Data Privacy Policy updated?

The ABBL reserves the right to replace or amend this policy at any time without prior notice. The latest version applicable will be the version published on the Website.

In order to be informed about how the ABBL processes the personal data of the Concerned Persons, we recommend consulting this statement periodically on the ABBL’s website: https://www.abbl.lu

16. Contact details

Any questions and requests relating to personal data should be addressed to the by e-mail (data.protection@abbl.lu).