What this site does not do
Most of what a privacy policy usually has to disclose does not apply here, for the simple reason that this site does not do it:
- No audience measurement. There is no Google Analytics, no equivalent, no counter. We do not know who visits, how many of you there are, or which pages get read.
- No advertising and no tracking. No pixel, no retargeting, no social network button, no profiling.
- No third-party content. The typefaces, the illustrations, the map and the video are served from our own site. Your browser never has to call another company to display a page, so no other company learns that you came here.
- No cookie banner – because there is nothing to consent to. See the cookies section below.
In short: if you never write to us, you leave nothing behind here beyond the technical trace that every web server keeps of every request.
Who is responsible
The data controller is Backes – Äre Kamäinbotzer, 26, Route de Luxembourg, L-6130 Junglinster, Luxembourg – info@backes-ramoneur.lu, +352 26 88 29 21.
We have not appointed a data protection officer. A company of our size and trade is not required to, and we would rather you wrote to the address above and got an answer from someone who knows your file.
What you send us through the contact form
The contact form asks for your name, your email address, the subject of your message and the message itself. The telephone number is optional; give it if you would rather we called.
What you send arrives as an email in our mailbox. It is not saved into a database on this site, and it does not feed a customer file, a newsletter or anything else. We use it to answer you, and that is all. You also receive a copy of your own message as an acknowledgement, so that you know it got through.
If your message cannot be sent – a field left empty, for instance – what you typed is held on the server for five minutes so that the form can hand it back to you filled in rather than blank. After that it is discarded.
What you send us when you book an appointment
The booking form asks for the service you need, your postcode, a preferred date and time slot, your name, your telephone number and your email address. The address of the property and a note are optional, though the address saves us a phone call.
These details reach us the same way: as an email, with a copy sent to you. We use them to confirm the appointment, to find the property and to carry out the job. Once the job is done, they become part of our ordinary customer record – the invoice, the sweeping certificate and the documents we are required to keep.
Protecting the forms from robots
The forms are protected without a captcha, so you never have to prove anything to a machine. Three things run behind them: a hidden field that only an automated script would fill in, a check that the form was not submitted within three seconds of loading, and a limit of five submissions per connection per hour.
For that last one, your IP address is not stored as such: it is reduced to a short fingerprint, kept only to count against the limit, and deleted after one hour.
What the server records
Like every web server, the one serving this site records the technical details of each request: an IP address, the date and time, the page requested and the identification string sent by your browser. These logs are kept by our host, and are used only to keep the site running and to look into abuse or an attack. [TO BE COMPLETED — how long the host keeps its server logs.]
Cookies and browser storage
This site sets no cookie on a visitor’s browser. Not one – which is why there is no banner asking you to accept any.
WordPress, which runs the site, does set cookies, but only for someone signing in to the administration area: that means us, not you.
One small thing is stored in your browser rather than on our server. If you close the charity pop-up, a single marker is written into your browser’s session storage so that it does not reappear on the next page. It contains no personal data, it never leaves your browser, and it disappears when you close the tab.
Why we are allowed to use this data
- Answering your message or your booking request – because you asked us to, and because it is what has to happen before a contract can be agreed.
- Carrying out and invoicing a job – performance of the contract between us.
- Keeping invoices, certificates and accounting records – a legal obligation.
- Keeping the site and the forms working, and stopping abuse – our legitimate interest in running a site that is not swamped by robots.
Who else sees it
Nobody buys, rents or is given your details for their own purposes. We do not sell data, and we do not share it with advertisers.
Two suppliers necessarily handle it in the course of their work: the company that hosts the site and the one that carries our email. The site is hosted by EURODNS, in Leudelange, Luxembourg – inside the European Union. [TO BE COMPLETED – name the email provider and confirm that it stores the data inside the European Union.] Beyond them, your details go to a third party only where the law requires it, or where a job requires it and you have agreed – an insurer or a municipality asking for a certificate, for example.
How long we keep it
- A message that leads nowhere – kept in the mailbox for up to one year, then deleted.
- A booking request that does not become a job – the same: one year.
- A job actually carried out – kept for as long as our accounting and tax obligations require, which in Luxembourg means ten years from the end of the financial year.
- The anti-spam fingerprint – one hour.
- The form values held after an error – five minutes.
- Server logs – kept by our host; see above.
Your rights
Under the General Data Protection Regulation, you can ask us at any time to:
- tell you what data we hold about you, and give you a copy;
- correct anything that is wrong or out of date;
- delete it, where nothing obliges us to keep it;
- restrict what we do with it, or object to it;
- hand it over in a portable form, or send it to someone else.
Write to info@backes-ramoneur.lu, or to the postal address at the top of this page. We answer within one month. We may ask you for something that shows the request really comes from you – we are not going to send someone else’s file to whoever asks for it.
If our answer does not satisfy you, you can lodge a complaint with the Luxembourg supervisory authority: the Commission nationale pour la protection des données (CNPD), Belvaux – cnpd.lu.
How we protect it
The site is served over an encrypted connection, so what you type into a form cannot be read on its way to us. Access to the administration area is restricted, its address is not the standard one, and the software is kept up to date. Your details sit in a mailbox and in our records, not in a database exposed on this site.
No system is beyond reach. If a breach ever affected your data and put you at risk, we would tell you, and we would tell the CNPD.
Changes to this policy
If what we do with your data changes, this page changes with it. The date of the last revision is shown at the top. Nothing here is applied retroactively to data already collected under an earlier version without telling you first.