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Privacy policy

Last updated: 9 October 2026

This privacy policy (the “Policy”) sets out how personal data are processed in connection with the website available at www.yws.lu and yws.lu, including all of its pages (the “Website”). It is provided pursuant to Articles 12 to 14 of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (the “GDPR”). It is an information notice and does not constitute a contract.

1.1. This Policy applies exclusively to the processing of personal data carried out by means of the Website. It does not apply to:

  • processing carried out by third parties on their own websites, platforms or services, including those to which the Website links (section 4.4);
  • personal data that you provide to Youth Work Synergy through a third-party service (such as a form hosted on Google Forms) or otherwise than through the Website. That processing is not carried out by means of the Website and is not covered by this Policy; the information required by Articles 13 and 14 GDPR is provided for it separately.

1.2. The applicable framework comprises the GDPR; the Loi du 1er août 2018 portant organisation de la Commission nationale pour la protection des données et mise en oeuvre du règlement (UE) 2016/679 […]; and the Loi modifiée du 30 mai 2005 relative aux dispositions spécifiques de protection de la personne à l’égard du traitement des données à caractère personnel dans le secteur des communications électroniques […].

1.3. The terms “personal data”, “processing”, “controller”, “joint controllers”, “processor”, “recipient” and “third party” have the meanings given to them in Articles 4 and 26 GDPR.

2. Controller and contact

2.1. The controller is Youth Work Synergy, association sans but lucratif (a.s.b.l.) governed by Luxembourg law, with its registered office at 16, rue Pierre Weydert, L-5891 Fentange and its office at 136-138, rue Adolphe Fischer, L-1521 Luxembourg (“YWS”, “we”, “us”).

2.2. Any question or request concerning personal data may be addressed to YWS:

3. Characteristics of the Website

3.1. The Website is a static website. It contains no forms, user accounts, newsletter, chat or comment function, and it uses no analytics, audience measurement, advertising, profiling or tracking technologies.

3.2. YWS does not, by means of the Website, store information or gain access to information already stored on your terminal equipment: the Website sets no cookies and uses no local storage or similar technologies. The language of the Website is part of the page address (/en/, /fr/). The fonts, images and 3D models of the Website are delivered from the Website itself.

3.3. The only third-party content embedded in the Website is the map on the home page (section 4.2).

4. Processing activities

4.1. Hosting and delivery of the Website

(a) Data concerned: your IP address and the approximate location derived from it; information about your browser, operating system and device; and the technical data of each request, such as the address of the page requested, the date and time of the request, the referring page as transmitted by your browser, and the response status.

(b) Purposes: delivering the pages of the Website to your browser; ensuring the security, availability and integrity of the Website; detecting, preventing and investigating abuse, attacks and technical faults.

(c) Legal basis: Article 6(1)(f) GDPR, the legitimate interest of YWS in operating a secure and functioning website. These data are necessary for the Website to be displayed; without them, it cannot be delivered to you.

(d) Processor: the Website is hosted by Vercel Inc., 440 N Barranca Avenue #4133 Covina, CA 91723 United States (privacy policy), which processes these data on behalf of YWS as a processor within the meaning of Article 28 GDPR.

(e) Retention: the technical data are kept for the period determined by the hosting service’s log settings and no longer than necessary for the purposes set out in point (b). They may be kept longer only where, and for as long as, necessary to investigate a specific security incident or to establish, exercise or defend legal claims.

4.2. Embedded map (Google Maps)

(a) The contact section of the home page contains a map of YWS’s office provided by Google (Google Maps). The map loads automatically when that section is about to appear on your screen; it does not load on the other pages of the Website, nor while only the upper part of the home page is displayed. When the map loads, your browser connects directly to Google’s servers.

(b) Data concerned: Google receives your IP address, information about your browser and device, and the address of the page on which the map is displayed. Google may store information on your terminal equipment or access information already stored there (for example cookies), in particular if you are signed in to a Google account.

(c) Purpose and legal basis: presenting the location of YWS’s office in an interactive and easily usable form, on the basis of the legitimate interest of YWS in doing so (Article 6(1)(f) GDPR).

(d) Responsibility: to the extent that YWS and Google jointly determine the purposes and means of the collection of these data by the embedded map and of their transmission to Google, they may be joint controllers for that collection and transmission only (Court of Justice of the European Union, judgment of 29 July 2019, Fashion ID, C-40/17). YWS does not receive, and has no access to, the data so collected, and has no influence over their further processing, for which Google alone is responsible. For users in the European Economic Area, the Google entity responsible is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Google’s processing, including its retention periods and any transfer of data outside the European Economic Area, is described in Google’s privacy policy.

(e) Your choices: the address of YWS’s office is also given in text next to the map, and the “Open in Google Maps” link opens Google Maps only when you select it. You can prevent the map from loading by blocking third-party content in your browser’s settings or with a browser extension.

4.3. Communications initiated from the Website

(a) The Website displays YWS’s email address and telephone numbers as links. Selecting such a link opens your own email or telephone application; the Website itself transmits nothing.

(b) Data concerned: when you write to or call YWS, YWS receives your contact details (such as your email address or telephone number, and your name if you give it), the content of your message and its date and time, together with any other information you choose to provide. Please do not send YWS special categories of personal data (Article 9 GDPR) unless this is strictly necessary for your request.

(c) Purposes and legal basis: answering and following up your request, on the basis of the legitimate interest of YWS in responding to the persons who contact it (Article 6(1)(f) GDPR); where your request concerns steps to be taken at your request before the conclusion of a contract (for example renting a property to YWS or a room from YWS), Article 6(1)(b) GDPR.

(d) Recipients: the members of YWS’s staff and volunteers who need the information to handle your request; the provider of YWS’s email service, as processor; and the telecommunications operators that carry the communication.

(e) Retention: for as long as necessary to handle your request and its follow-up. Correspondence that becomes part of a contractual relationship is kept for the duration of that relationship and of the applicable limitation periods. Otherwise it is deleted, unless longer retention is required by law or is necessary to establish, exercise or defend legal claims.

(a) The Website contains links to third-party websites and services, including Google Forms and Google Drive, Facebook, Instagram and LinkedIn, the websites of YWS’s partners, tecpractices.eu, and the websites credited for the materials used on the Website. The Website loads no content from these third parties before you select a link.

(b) Once you follow such a link, the third party processes your personal data under its own responsibility and its own privacy policy. YWS is not responsible for the content of third-party websites or for their processing of personal data.

4.5. Images of identifiable persons published on the Website

(a) The Website publishes photographs taken during YWS’s projects and events, some of which show identifiable persons.

(b) Purpose and legal basis: presenting YWS’s activities. The legal basis is the consent of the persons shown or the legitimate interest of YWS.

(c) Retention: for as long as the photograph is published on the Website. Any person shown in a photograph may ask for its removal or object to its publication by writing to contact@yws.lu.

5. Recipients

5.1. Within the limits of what is necessary for the purposes described in section 4, personal data may be disclosed to:

  • Vercel Inc., as YWS’s hosting processor (section 4.1);
  • Google, under the conditions described in section 4.2;
  • the provider of YWS’s email service and the telecommunications operators (section 4.3);
  • public authorities, courts and YWS’s professional advisers bound by confidentiality, where required by law or necessary to establish, exercise or defend legal claims.

5.2. YWS does not sell personal data and does not disclose them to third parties for advertising purposes.

6. Transfers outside the European Economic Area

6.1. Vercel Inc. is established in the United States. Vercel states that its transfers rely on its certification under the EU-U.S. Data Privacy Framework and on the standard contractual clauses adopted by the European Commission (Decision (EU) 2021/914).

6.2. Transfers by Google are governed by section 4.2(d).

6.3. Information on the safeguards relied upon, and on how to obtain a copy of them, may be requested from YWS at the contact details in section 2.

7. Cookies and similar technologies

7.1. The Website itself stores no information on your terminal equipment and accesses no information stored there.

7.2. Only the embedded map (section 4.2), once loaded, may enable Google to do so, under the conditions set out in that section.

8. Security

8.1. YWS implements technical and organisational measures appropriate to the risks, in particular: delivery of the Website over encrypted connections (HTTPS); a static Website with no database and no server-side processing of data entered by visitors; and security headers that disable access to the camera, microphone and geolocation, limit the information transmitted to other websites as the referring page, and restrict the embedding of the Website in other websites.

8.2. No transmission of data over the Internet can be guaranteed to be entirely secure. YWS will act in accordance with Articles 33 and 34 GDPR in the event of a personal data breach.

9. Your rights

9.1. Under the conditions and within the limits laid down by the GDPR, you have the right to:

  • obtain confirmation as to whether personal data concerning you are processed, and access to them (Article 15);
  • have inaccurate data rectified and incomplete data completed (Article 16);
  • obtain the erasure of your data (Article 17);
  • obtain the restriction of processing (Article 18);
  • receive the data you have provided in a structured, commonly used and machine-readable format and have them transmitted to another controller, where the processing is based on your consent or on a contract and is carried out by automated means (Article 20);
  • withdraw your consent at any time where processing is based on consent, without affecting the lawfulness of processing carried out before its withdrawal (Article 7(3)).

9.2. To exercise these rights, contact YWS at the contact details in section 2. Where YWS has reasonable doubts as to the identity of the person making a request, it may request additional information necessary to confirm it (Article 12(6) GDPR).

9.3. YWS responds without undue delay and in any event within one month of receipt of the request. That period may be extended by two further months where necessary, taking into account the complexity and number of requests; you will be informed of any extension, with the reasons for it, within one month of receipt of the request. Requests are free of charge; where requests are manifestly unfounded or excessive, in particular because of their repetitive character, YWS may charge a reasonable fee or refuse to act on them (Article 12(5) GDPR).

9.4. As regards the data collected by the embedded map (section 4.2), you may exercise your rights in respect of each controller (Article 26(3) GDPR). As YWS does not receive those data, requests concerning their further processing are answered by Google.

Right to object

Where YWS processes personal data concerning you on the basis of its legitimate interests (Article 6(1)(f) GDPR), you have the right to object to that processing at any time, on grounds relating to your particular situation (Article 21 GDPR). YWS will then no longer process the data unless it demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is necessary for the establishment, exercise or defence of legal claims.

10. Right to lodge a complaint

Without prejudice to any other administrative or judicial remedy, you have the right 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 (Article 77 GDPR). In Luxembourg, the supervisory authority is the Commission nationale pour la protection des données (CNPD), 1, avenue du Rock’n’roll, L-4361 Esch-sur-Alzette, tel. (+352) 26 10 60-1, cnpd.public.lu.

11. Automated decision-making

YWS takes no decision based solely on automated processing, including profiling, within the meaning of Article 22 GDPR by means of the Website.

12. Children

The Website has no feature designed to collect personal data from children. A holder of parental responsibility who believes that a child has provided personal data to YWS may ask YWS to erase them at the contact details in section 2.

13. Changes to this Policy

YWS may amend this Policy at any time, in particular to reflect changes to the Website, to its processing or to the applicable law. The version in force is the one published on this page; the date of its last update is shown at the top of the page.

14. Language and applicable law

This Policy is drawn up in English and in French. In the event of any discrepancy between the two versions, the French version prevails. This Policy is governed by the law of the Grand Duchy of Luxembourg, without prejudice to the mandatory provisions of the GDPR and to the rights you hold under them.