Privacy Policy
Last updated: February 2026
1. Data Controller
The data controller for personal data collected via the website letzagents.lu is:
Clickbye Sàrl
85 rue de Reckenthal, L-2410 Strassen, Luxembourg
RCS Luxembourg: B211848
Email: moien@letzagents.lu
2. Data Collected
We collect a minimum of data, only when necessary:
- Anonymous analytics data : pages visited, session duration, country of origin, device type. No personally identifiable data is collected (no IP address, no browser fingerprint).
- Appointment booking data : name, email address, phone number, company name, desired services and indicative budget. This data is voluntarily provided by users when booking a time slot.
3. Analytics (Umami)
We use Umami, an open-source analytics solution, self-hosted on our own servers at Hetzner (European Union).
Umami is designed with privacy in mind:
- No cookies are stored in your browser
- No IP address is collected or stored
- No browser fingerprint is generated
- No personally identifiable data is processed
- Data is aggregated and anonymous by nature
No data is shared with third parties. Umami is GDPR compliant without requiring prior consent, as it does not process any personal data.
4. Appointment Booking (Cal.com)
Our appointment booking system uses Cal.com, an open-source solution self-hosted on our own servers at Hetzner (European Union).
When booking a time slot, the following data is collected:
- Name
- Email address
- Phone number
- Company name
- Desired services
- Indicative budget
- Additional notes (optional)
This data is used exclusively to organise and prepare our meeting. It is neither sold nor shared with third parties.
5. Legal Basis for Processing
In accordance with the GDPR (EU Regulation 2016/679), each processing activity is based on a legal basis:
| Processing | Legal basis | GDPR reference |
|---|---|---|
| Analytics (Umami) | Legitimate interest | Art. 6(1)(f) |
| Appointment booking (Cal.com) | Consent | Art. 6(1)(a) |
6. Hosting and Security
All data is hosted on servers located in the European Union (Germany and Finland) at Hetzner Online GmbH, certified ISO 27001.
Our solutions (Umami, Cal.com) are self-hosted on our own infrastructure. No data passes through US cloud services (no Google, no Amazon, no Microsoft).
7. Data Transfers
No data transfers outside the European Union are made. All our servers, tools and subcontractors are located within the EU. No company subject to the US Cloud Act has access to your data.
8. Data Retention
Data retention periods are as follows:
- Analytics data (Umami) : retained in aggregated and anonymous form, without time limit (no personal data is involved).
- Appointment data (Cal.com) : retained for the duration of the business relationship, then deleted within 12 months after the last contact, unless a longer legal retention obligation applies.
9. Your Rights
Under the GDPR, you have the following rights regarding your personal data:
- Right of access : obtain a copy of your personal data
- Right to rectification : correct inaccurate or incomplete data
- Right to erasure : request deletion of your data
- Right to data portability : receive your data in a structured format
- Right to object : object to the processing of your data
- Right to withdraw consent : withdraw your consent at any time
To exercise these rights, contact us at moien@letzagents.lu. We will respond within 30 days.
You also have the right to lodge a complaint with the Commission Nationale pour la Protection des Données (CNPD) of Luxembourg: cnpd.public.lu
11. Changes to This Policy
We reserve the right to modify this privacy policy at any time. The date of the last update is indicated at the top of this page. We encourage you to check this page regularly.
12. Contact
For any questions regarding this privacy policy or the processing of your personal data, contact us at moien@letzagents.lu.