Privacy policy

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Foreword

HOTCITY S.A. cares about your privacy.

On this page you will find all the information on how HOTCITY S.A. is collecting, processing and disclosing your personal data, collected on this Website and our portals.

Personal data we collect about you

We do everything possible to ensure to provide our clients with a confident service by processing your data in a transparent way as well as in strict compliance with applicable regulations in accordance with your own preferences.

We assure you that your personal data will never be sold to a third party, for any reason. 

YOU HAVE SENT US A MESSAGE VIA OUR CONTACT FORM

Following data may be collected :

  • Last name
  • First name
  • E-mail address

The processing of your personal data is processed in the context of our business relations. The processing of your personal data is carried out pursuant to Article 6.1.f. (processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child) of the European regulation Number 2016/679.

You have communicated your data to us

The personal data are stored for 3 years from the date of their collection and will then be deleted.

Your personal data won’t be disclosed to a third party.

YOU HAVE CREATED A CITYWIFI ACCOUNT

Following data may be collected :

  • Username
  • Password
  • Mobile phone number

The processing of your personal data by HOTCITY S.A. is carried out pursuant to Article 6.1.b. (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) and Article 6.1.f. (processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child) of the European regulation Number 2016/679. Some data is collected for statistical purposes.

You have communicated your data to us

The personal data are stored for 6 months from the date of the request for the deletion of your account.

Your personal data may be transferred to a third party :

  • to a mobile operator, in the context of sending a verification code for your “citywifi” account;
  • to any administrative or judicial authority in order to comply with legal obligations and law enforcement requests.

YOU HAVE PURCHASED A CITYWIFI PREMIUM SUBSCRIPTION

Following data may be collected :

  • Username
  • Password
  • Mobile phone number
  • Method of payment

The processing of your personal data by HOTCITY S.A. is carried out pursuant to Article 6.1.b. (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) and Article 6.1.f. (processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child) of the European regulation Number 2016/679. Some data is collected for statistical purposes.

You have communicated your data to us

The personal data are stored for accounting purposes for 10 years from the date of the last payment.

Your personal data may be transferred to a third party :

  • to a payment service provider, in order to process your payment ;
  • to any administrative or judicial authority in order to comply with legal obligations and law enforcement requests.

YOUR DEVICE GOT CONNECTED TO THE CITYWIFI FREE/PREMIUM NETWORK

Following types of information are collected : 

  • information regarding your device in our Wi-Fi network : MAC address, IP address ;
  • the domain names of the pages you visit ;
  • Surfing session information (start time, end time, volume of traffic generated,…).

The processing of your personal data by HOTCITY S.A. is carried out pursuant to Article 6.1.b. (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) and Article 6.1.f. (processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child) of the European regulation Number 2016/679. Some data is collected for statistical purposes.

This data is automatically generated by your device when it gets connected to the network.

The personal data are stored for 6 months from the date of their collection.

Your personal data won’t be disclosed to a third party.

Your data protection rights

You have the right to request access to the personal data HOTCITY S.A. is collecting and processing about you.
Please send your enquiry as well as a copy of your ID card (which will be deleted as soon as your enquriy has been processed) by e-mail to the following address : rgpd@hotcity.lu.

You have the right to obtain the rectification of inaccurate personal data collected by HOTCITY S.A.
Please send your enquiry as well as a copy of your ID card (which will be deleted as soon as your enquriy has been processed) by e-mail to the following address : rgpd@hotcity.lu.

You have the right to obtain the erasure of your personal data collected by HOTCITY S.A.
Please send your enquiry as well as a copy of your ID card (which will be deleted as soon as your enquriy has been processed) by e-mail to the following address : rgpd@hotcity.lu.

Nevertheless, HOTCITY S.A. might decline your request :

  • for compliance with a legal obligation which requires processing by law to which HOTCITY S.A. is subject ;
  • for the establishment, exercise or defense of legal claims

You have the right to ask for a restriction of processing your personal data.
Please send your enquiry as well as a copy of your ID card (which will be deleted as soon as your enquriy has been processed) by e-mail to the following address : rgpd@hotcity.lu.

You have the right to object to the processing of your personal data by HOTCITY S.A.
Please send your enquiry as well as a copy of your ID card (which will be deleted as soon as your enquriy has been processed) by e-mail to the following address : rgpd@hotcity.lu.

You have the right to revoke your consent to the processing of your personal data by HOTCITY S.A.
Please send your enquiry as well as a copy of your ID card (which will be deleted as soon as your enquriy has been processed) by e-mail to the following address : rgpd@hotcity.lu.

You have the right to file a complaint with the National Commission for Data Protection (CNPD).

Protection of your personal data

HOTCITY S.A implements appropriate and reasonable security measures in light of the risks posed by the processing carried out in order to protect your data against destruction, loss, modification, disclosure or unauthorized access and any other form of illegal processing.

All our employees with access to your personal data as part of their jobs are bound by strict confidentiality obligations. They only access the data they need to do their job and are regularly made aware of and trained on the compliance and security rules applicable to your personal data.

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