It is important that you read this privacy notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your personal data. This privacy notice replaces any former privacy notice..

Changes may occur in the way we process information about you. In case these changes oblige us to update our privacy notice, we will bring this to your attention to the extent possible. The latest version will always be available here.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

The Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites (and in particular the subsequent processing operations they may carry out after having received the personal data) and are not responsible for their own privacy statements. When you leave the Website, we encourage you to read the privacy notice of every third-party website you visit. For more information on the use of cookies by the Website, please read our Cookie Policy available on this Website or by clicking on the following link.

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not refer to anonymous data, namely information which do not relate to an identified or identifiable natural person.

We may collect, use, store and transfer different kinds of personal data about you or your child which we have grouped together as follows:

Identity Data includes parents first name, parents last name, children first name, children last name, children’s photographs, address, postal code, city, staff number, country of residence, office number.

Contact Data includes email address, mobile phone number, work phone number, home phone number.

Transaction Data includes details about payments to and from you and other details of Services you have subscription with us.

Technical Data includes internet protocol (IP) address, cookies, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Website. For more information on the use of cookies by the Website, please read our Cookie Policy available on this Website or by clicking on the following link.

Profile Data includes your username and password, your subscription made by you, your interests, preferences, feedback and survey responses.

Usage Data includes information about how you use the Website and Services.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. However we may collect data concerning your child’s health status in limited circumstances where it is necessary to adapt the Services in respect of such health status. In this case Aggregated Data is not anonymized.

We may also collect and process personal data you provide via the text box available in our online contact form. We do not want to process any Special Categories of Personal Data via such text box. Therefore, if you deliberately include such Special Categories of Personal Data about yourself (or other persons) in the incoming communication sent to us, we will consider that we have received the consent to use it for the purpose of responding to your query. To the extent we consider such Special Categories of Personal Data not useful for the purpose of handling your request, we endeavour to delete it.

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with Services). In this case, we may have to cancel a Service you have with us but we will notify you if this is the case at the time.

We use different methods to collect personal data from and about you including through:

Direct interactions. You may give us your Identity and Contact Data by filling in enrolment forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• complete the forms on the Website contact page;
• complete the forms on the Enrolment page and apply/subscribe to our Services;
• create an account on the Website;
• fill in surveys or give us some feedback.

Automated technologies or interactions. As you interact with the Website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. For more information on the use of cookies by the Website, please read our Cookie Policy available on this Website or by clicking on the following link.

Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:

• Technical Data from the following parties:
  • Google Analytics
• Transaction Data from providers of technical and payment services.

We will only process your personal data when we have a legal ground to do so as follows:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests (our legitimate interests are for example seeking maximum efficiency (including IT efficiency and security) for a continuous functioning of the Website and responding to your requests).
• Where we need to comply with a legal or regulatory obligation.
• Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to processing your child’s health status under limited circumstances. You have the right to withdraw such consent at any time by contacting us.

We have listed below, in a table, the purposes for which we use your personal data, the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below:

Purpose/Activity	Type of personal data	Lawful basis for processing
To verify eligibility of the applicant to the Services, to manage subscription to the Services and related payment(s)	(a) Identity (b) Contact (c) Profile (d) Transaction	Performance of contract or in order to take steps at the request of the data subject prior to entering into a contract Necessary to comply with a legal obligation (tax reporting, bookkeeping) Necessary for our legitimate interests (billing management, complaint management)
To allow you to leave a comment/message on the Website.	(a) Identity (b) Contact	Performance of a contract with you Necessary for our legitimate interests
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy notice (b) Asking you to give feedback or fill in a survey	(a) Identity (b) Contact (c) Profile	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests ( improving our Services and adapting our Services to the needs of the users)
To administer and protect our business and the Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	All personal data	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud (b) Necessary to comply with a legal obligation
To adapt the Services in respect of the health status of a child in limited circumstances.	Information as to the necessity for a child to be accompanied by an adult in the bus	The processing is made with the consent of the parents or persons exercising legal authority (in which case the consent may be withdrawn at any time, without this affecting the processing carried out before such withdrawal and without prejudice to retention or processing that may be required from us by law)
To use data analytics to improve the Website, our Services	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our services, to keep the Website updated and relevant)

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

Your personal data are or may be transmitted by us to the following recipients to the extent that such disclosure or transmission is necessary for satisfying the aforementioned purposes:

1. Internal governance bodies such as ATSEEE’s management committee

2. Hosting provider (EU)

3. IT System administrator located in Ukraine (responsible for maintaining and monitoring ATSEEE IT server): personal data are transferred to the IT System administrator on the basis of standard data protection clauses approved by the European Commission in compliance with Article 46.2 of the GDPR,

4. Transport companies (Luxembourg): only where there is a complaint from the parents (the communication received by ATSEEE from the concerned parents in this regard is forwarded to the transport companies)

5. Our auditors and legal or other advisers located in Luxembourg

6. To the extent necessary, public, governmental, administrative, supervisory, regulatory or judicial entities in the EU

7. The following external third parties (EU) (only to concerned entity linked to the data subject applying to the service and only for the purpose to verify the eligibility of the applicant to the school bus transport service):

• European Commission
• European Parliament
• European Court of Justice
• European Court of Auditors
• European School Luxembourg 1
• European School Luxembourg 2
• European Investment Bank
• European Investment Fund
• Eurocontrol
• Translation Centre for the Bodies of the European Union
• The Consumers, Health, Agriculture and Food Executive Agency
• Pensioner

In relation to countries which do not offer a similar level of data protection as within the European Union, we have implemented appropriate safeguards according to the Data Protection Laws as mentioned above. You can obtain from us more information in respect of transfers outside of the European Economic Area upon request.

How long will you use my personal data for?

We will retain your personal data for as long as necessary to fulfil the purposes we collected it for , subject to the legal periods of limitation and to the situations where applicable laws require or allow personal data to be retained for a certain period of time after the termination of the contractual and commercial relationship (such as the legal obligation to keep accounting documents for a period of 10 years).

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Without prejudice to the generality of the foregoing, we:

• delete personal data (Identity and Contact Data) on a yearly basis (every December) where you are not subscribing anymore to our Services;
• retain personal data in relation to payments (Transaction Data) only for the time of completion of the payment transaction;
• delete personal data provided via contact form (Identity Data, Contact Data and personal data inserted in the message field) one (1) month after you provide such information to the extent we have reverted to you.

We may also keep and process personal data about you after the termination of our contractual relationship for specific purposes such as the compliance with legal obligations or the establishment, exercise or defence of legal claims.

In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Under certain circumstances, you have rights under Data Protection Laws in relation to your personal data.

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

[Obtain from us a copy of, or access to, any balancing test that has been conducted in relation to the processing of personal data based on our legitimate interests.]

Further information on these rights can be can be found on the CNPD website.

You have the right to lodge a complaint at any time with the National Commission for Data Protection in Luxembourg (CNPD : www.cnpd.public.lu) or with any other data protection authority depending on your place of residence or place of work. We would, however, appreciate the chance to deal with your concerns before you approach the CNPD or any other relevant supervisory authority, so do not hesitate to contact us in the first instance.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.