DEFINITIONS
“Cookies” means the definition given in Section 1 of this Policy.
“Personal Data” means any information relating to a natural person who can be identified, directly or indirectly.
“Retention Period” means the period of time for which we retain your Personal Data.
“We” or “Us” means The Luxembourg House of Financial Technology acting as data controller.
“Our Site” means the site, application, platform that you use and for which this policy applies.
“Data controller” means the legal entity (company, municipality, etc.) or natural person who determines the purposes and means of a processing operation, i.e. the objective and the way it is carried out. In practice and in general, it is the legal person embodied by its legal representative.
“Subcontractor” means the natural or legal person (company or public body) who processes data on behalf of another body (“the data controller”), in the context of a service or provision.
“You” means the users of our Site.
PREAMBLE
A. SCOPE
The purpose of this Cookie Policy is to inform you about the use of Cookies operated by Our Site https://lhoft.com (i.e. data by which you may be directly or indirectly identified) as well as of your rights in accordance with the Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 (the GDPR), related guidance and national laws complementing the GDPR (together the Data Protection Legislation) and applies to you if you are an individual related to a co-worker or a fellow (such as legal representative, contact person, director, employee or intern) (the Co-worker, the Fellow or you).
You can find below more information on: who is the controller of your personal data (B), what is a cookie (C), what cookie do we use (D),If we share data to third countries (E), the options to manage your consent regarding cookies (G), how you can remove cookies (H) and the update to this policy (I).
B. WHO IS THE CONTROLLER OF YOUR PERSONAL DATA?
You are hereby informed and acknowledge that your personal data may be collected and processed (i.e. used, stored, transmitted, etc.) by:
The Fondation LHoFT, a Luxembourg “foundation,” having its registered address at 9, rue du Laboratoire, L-1911 Luxembourg, Grand Duchy of Luxembourg, registered with the Luxembourg Register of Commerce and Companies under the registration number G239, hereby represented by by Nasir Zubairi (the LHoFT, we or us).
in accordance with the provisions of this Privacy Notice and the Data Protection Legislation.
We act as Data Controller when processing your Personal Data (as defined below).
If you have any questions or comments or want to exercise your rights detailed above, you may contact us by post at our registered address indicated above or by e-mail using the following address [email protected].
C. WHAT IS A COOKIE?
A cookie is a small file stored by a server in the terminal (computer, telephone, etc.) of a user and associated with a web domain (i.e. in most cases with all the pages of the same website). This file is automatically sent back when the user contacts the same domain again.
Cookies have multiple uses: they can be used to memorize your customer ID with a merchant site, the current contents of your shopping cart, the language in which the web page is displayed, an identifier that allows us to track your navigation for statistical or advertising purposes, etc. Some of these uses are strictly necessary for the functionalities expressly requested by the user or for the establishment of the communication and are therefore exempt from consent. Others, which do not correspond to these criteria, require the user’s consent before reading or writing.
The distinction between “third-party” and “first-party” cookies is technical. When a user visits a website, he/she is in practice consulting a “domain” which generally ends with a .com or .fr extension (for example, monsite.com is a domain), the content can be transmitted from the domain he/she is visiting or via other domains that he/she has not entered himself/herself and that belong to third parties. Indeed, each cookie is associated with a domain and sent or received each time the browser will “call” that domain.
The “internal” cookies are deposited by the site consulted by the Internet user, more precisely on the domain of the site. They can be used for the proper functioning of the site or to collect personal data to track the user’s behavior and serve advertising purposes.
“Third-party” cookies are cookies deposited on domains other than that of the main site, managed by third parties who have been questioned by the site visited and not by the user himself: these cookies may also be necessary for the proper functioning of the site, but they are used to enable the third party to see which pages have been visited on the site in question by a user and to collect information about him, particularly for advertising purposes.
The fact that cookies are “internal” or “third party” is a technical distinction that has no consequence on whether or not consent is required. In practice, a large majority of “third-party” cookies have purposes that require consent (for example, advertising), but one can also find “third-party” cookies that are indeed strictly necessary for a functionality expressly requested by the user and therefore exempt from consent. This is the case, for example, of cookies used solely for federated authentication (when a single account allows access to several sites).
D. WHAT COOKIES DO WE USE?
The Cookies used on our Site are classified as follows:
- Strictly necessary cookies
- Preference cookies
- Statistic cookies
- Marketing cookies
a. Strictly necessary Cookies
The technical storage of or access to such cookies is strictly necessary for the sole purpose of enabling the use of a specific service explicitly requested by the subscriber or user, or for the sole purpose of carrying out the transmission of a communication over an electronic communications network.
Such cookies are set in response to actions made by visitors which amount to a request for services, such as setting privacy preferences, personalizing our content for you (for example), your choice of language or region), logging in or filling in forms. [These cookies only store anonymous data. These cookies cannot be disabled and if you set your browser to block these cookies, this may cause parts of our website to not function properly.]
Your consent is not required for depositing these Cookies in accordance with the applicable regulations.
| Cookie name | Provider | Type | Purpose | expiration |
| CookieConsent | Cookiebot | HTTP | Stores the user’s cookie consent state for the current domain | 1 year |
| PHPSESSID [x2] | Albumizr www.ume.solutions | HTTP | Preserves user session state across page requests. | Session |
| elementor | lhoft.com | HTML | Used in context with the website’s WordPress theme. The cookie allows the website owner to implement or change the website’s content in real-time. | Persistent |
| JSESSIONID | New Relic | HTTP | Preserves users states across page requests. | Session |
| shield-notbot-nonce | peermountain.com | HTTP | This cookie is used to distinguish between humans and bots. | 1 day |
| __cf_bm | Vimeo | HTTP | This cookie is used to distinguish between humans and bots. This is beneficial for the website, in order to make valid reports on the use of their website. | 1 day |
| cookieyes-consent | cdn-cookieyes.com | HTTP | Determines whether the user has accepted the cookie consent box. | 1 year |
| CONSENT | YouTube | HTTP | Used to detect if the visitor has accepted the marketing category in the cookie banner. This cookie is necessary for GDPR-compliance of the website. | 2 years |
b. Preference cookies
Preference cookies enable a website to remember information that changes the way the website behaves or looks, like your preferred language or the region that you are in.
| Cookie Name | Provider | Type | Purpose | expiration |
| pll_language | active-asset-allocation.com | HTTP | This cookie is used to determine the preferred language of the visitor and sets the language accordingly on the website, if possible. | 1 year |
c. Statistic cookies
Statistic cookies help website owners to understand how visitors interact with websites by collecting and reporting information anonymously.
Audience measurement cookies allow us to measure the traffic or performance of our Site. They allow us to measure the number of times a page is viewed, to know which pages are the most popular and to see how visitors navigate our Site to improve their experience.
The use of these cookies requires your prior consent. You can refuse them at any time or withdraw your consent if you have previously given it.
| Cookie name | Purpose | Expiry | Provider |
| _ga [x3] | Registers a unique ID that is used to generate statistical data on how the visitor uses the website. | 2 years | |
| _ga_# [x2] | Used by Google Analytics to collect data on the number of times a user has visited the website as well as dates for the first and most recent visit. | 2 years | |
| _gat [x2] | Used by Google Analytics to throttle request rate | 1 day | |
| _gid [x3] | Registers a unique ID that is used to generate statistical data on how the visitor uses the website. | 1 day | |
| geo | Saves the user’s current geographical location based on the user’s IP address. | Session | Apple |
| __qca | Collects data on the user’s visits to the website, such as the number of visits, average time spent on the website and what pages have been loaded with the purpose of generating reports for optimising the website content. | 1 year | Quantcast |
| _dlt [x2] | Sets a unique ID for the session. This allows the website to obtain data on visitor behaviour for statistical purposes. | 1 day | Quantcast |
| collect | Used to send data to Google Analytics about the visitor’s device and behavior. Tracks the visitor across devices and marketing channels. | Session | |
| job_listing_#_# | pending | Session | lhoft.com |
| __qca | Collects data on the user’s visits to the website, such as the number of visits, average time spent on the website and what pages have been loaded with the purpose of generating reports for optimising the website content. | Persistent | Issuu |
| qcSes | Collects data on the user’s visits to the website, such as the number of visits, average time spent on the website and what pages have been loaded with the purpose of generating reports for optimising the website content. | Session | Issuu |
| browser_id | Used to recognise the visitor’s browser upon reentry on the website. | 5 years | |
| vuid | Collects data on the user’s visits to the website, such as which pages have been read. | 2 years | Vimeo |
| td | Registers statistical data on users’ behaviour on the website. Used for internal analytics by the website operator. | Session |
d. Marketing cookies
Marketing cookies are used to track visitors across websites. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third-party advertisers.
Targeted advertising Cookies allow us to show you relevant ads that best match your interests. These Cookies may include Social Network Cookies that allow you to share content but also to access our dedicated pages on social networks on LinkedIn, Twitter, Instagram, and YouTube.
Social networks can identify you through this process only if your account on that social network has been active on your terminal.
Targeted advertising Cookies only identify your browser and/or device. These Cookies collect information about the page from which you accessed the Site, the page on which our advertisement was presented to you for example Facebook, Instagram, YouTube.
These Cookies require your prior consent. If you have given your consent, you may withdraw it at any time.
| Cookie name | Purpose | Expiry | Provider |
| giphyPingbackId | Used to track the visitor’s usage of GIFs – This serves for analytical and marketing purposes. | Session | Giphy Support |
| ads/ga-audiences | Used by Google AdWords to re-engage visitors that are likely to convert to customers based on the visitor’s online behaviour across websites. | Session | Giphy Support |
| iutk | Recognises the user’s device and what Issuu documents have been read. | Session | Issuu |
| mc | Collects data on the user’s visits to the website, such as what pages have been loaded. The registered data is used for targeted ads.. | 13 months | Quantcast |
| i/jot/embeds | Sets a unique ID for the visitor, that allows third party advertisers to target the visitor with relevant advertisement. This pairing service is provided by third party advertisement hubs, which facilitates real-time bidding for advertisers | Session | |
| LAST_RESULT_ENTRY_KEY | Used to track user’s interaction with embedded content. | Session | YouTube |
| LogsDatabaseV2:V#||LogsRequestsStore | pending | Persistent | YouTube |
| nextId | Used to track user’s interaction with embedded content. | Session | YouTube |
| remote_sid | Necessary for the implementation and functionality of YouTube video-content on the website. | Session | YouTube |
| requests | Used to track user’s interaction with embedded content. | Session | YouTube |
| ServiceWorkerLogsDatabase#SWHealthLog | Necessary for the implementation and functionality of YouTube video-content on the website | Persistent | YouTube |
| TESTCOOKIESENABLED | Used to track user’s interaction with embedded content. | 1 day | YouTube |
| VISITOR_INFO1_LIVE | Tries to estimate the users’ bandwidth on pages with integrated YouTube videos. | 180 days | YouTube |
| VISITOR_PRIVACY_METADATA | Pending | 180 days | YouTube |
| YSC | Registers a unique ID to keep statistics of what videos from YouTube the user has seen. | Session | YouTube |
| yt.innertube::nextId | Registers a unique ID to keep statistics of what videos from YouTube the user has seen. | Persistent | YouTube |
| ytidb::LAST_RESULT_ENTRY_KEY | Stores the user’s video player preferences using embedded YouTube video | Persistent | YouTube |
| YtIdbMeta#databases | Used to track user’s interaction with embedded content. | Persistent | YouTube |
| yt-remote-cast-available | Stores the user’s video player preferences using embedded YouTube video | Session | YouTube |
| yt-remote-cast-installed | Stores the user’s video player preferences using embedded YouTube video | Session | YouTube |
| yt-remote-connected-devices | Stores the user’s video player preferences using embedded YouTube video | Persistent | YouTube |
| yt-remote-device-id | Stores the user’s video player preferences using embedded YouTube video | Persistent | YouTube |
| yt-remote-fast-check-period | Stores the user’s video player preferences using embedded YouTube video | Session | YouTube |
| yt-remote-session-app | Stores the user’s video player preferences using embedded YouTube video | Session | YouTube |
| yt-remote-session-app | Stores the user’s video player preferences using embedded YouTube video | Session | YouTube |
| yt-remote-session-name | Stores the user’s video player preferences using embedded YouTube video | Session | YouTube |
e. Unclassified cookies
Unclassified cookies are cookies that we are in the process of classifying, together with the providers of individual cookies.
| Cookie Name | Provider | Type | Purpose | expiration |
| jallery_uid | Albumizr | HTTP | Pending | 400 days |
| sails.sid | moneyfellows.com | HTTP | Pending | Session |
E. TRANSFERS OF DATA TO THIRD COUNTRIES
The following cookies transfer the following data to third countries:
| Providers | Third country |
| Cookiebot | Ireland |
| United States |
F. HOW CAN I MANAGE MY CONSENT ?
When you access our Site for the first time, a Cookie configuration banner appears. The purpose of this banner is to inform you but also to collect your consent to the deposit of Cookies on your terminal.
You can choose which statistics and marketing cookies we can set by sliding the buttons as follows:
This banner will remain visible if you have not expressed your choice (acceptance, rejection, or personalized settings). In the absence of an expressed choice, no other Cookie, apart from the strictly necessary Cookies, will be installed on your terminal.
If you reject the deposit of Cookies, a refusal Cookie will be installed on your terminal to record your choice. The refusal Cookie will be valid for a period of 12 months, after which you will be asked to confirm your choice regarding the deposit of Cookies in your terminal. If however you were to delete the Cookie of refusal, it will then be asked to you to express again your choice by the means of the banner of Cookie.
You can at any time review and/or change your preferences by clicking on “ Manage Consent” at the bottom of the webpage.
General information on your rights with respect to the processing of your personal data is available here
The recipient of the personal data from the cookies is our Subcontractor in charge of the maintenance of the website. We entered a data protection agreement (DPA) with this subcontractor to ensure that the data is processed under the best possible conditions of security and confidentiality.
G. HOW CAN I REMOVE COOKIES ?
You can remove all cookies that are already on your device by clearing the browsing history of your browser. This will remove all cookies from all websites you have visited.
Be aware though that, by doing so, you may also lose some saved information (e.g., saved login details site preferences).
You can find more information on how to remove cookies on browsers usually used by following the below links:
- Google Chrome: https://support.google.com/chrome/answer/95647?hl=en&hlrm=en
- Internet Explorer: https://support.microsoft.com/en-us/help/278835/
- Mozilla Firefox: https://support.mozilla.org/en-US/kb/enhanced-tracking-protection-firefox-desktop?redirectslug=enable-and-disable-cookies-website-preferences&redirectlocale=en-US
- Microsoft Edge: https://support.microsoft.com/en-us/microsoft-edge/delete-cookies-in-microsoft-edge-63947406-40ac-c3b8-57b9-2a946a29ae09
- Opera: https://help.opera.com/en/latest/web-preferences/#cookies
- Safari: http://help.apple.com/safari/mac/8.0/#/sfri11471
H. CHANGES TO THIS COOKIE POLICY
This policy is as of September 2023 and we reserve the right to update it, at our discretion in case of our use of cookies would change.
We may modify this Cookie Policy from time to time. This modification may occur in particular in the event of a change in the regulations applicable in the European Union or in the Grand Duchy of Luxembourg. Please note that any change to this Policy will require you to re-express your consent for the various applicable Cookies through the Cookie management panel.
I. WHO CAN I CONTACT FOR ANY QUESTION I MAY HAVE?
Any questions on cookies and/or the content of this privacy policy may be address to […] who can be reached at [email protected] or via the contact form.
For information on your rights regarding the protection of personal data, you can find our Privacy Policy here.
