Privacy Policy

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

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 : company name, services you are interested in, planned budget, free-text notes, name, email address, phone number and chosen time slot, plus the browsing language and any campaign parameters present in the URL. This data is entered voluntarily, step by step, in the appointment booking form.

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.

Booking an appointment on letzagents.lu is done through a form built directly into the website. No external booking tool is used.

Data collected. The form is completed in several steps. The data you enter is saved at each validated step (clicking the button to the next step), not only when the form is finally submitted:

• Step 1: company name, services you are interested in, planned budget, free-text notes
• Step 2: name, email address, phone number
• Step 3: chosen time slot

The browsing language is always recorded as well, along with campaign parameters (utm_*, gclid, fbclid) if they are present in the page URL.

Purposes. This data is used to process your appointment request. If the form is not completed, it allows us to get back to you about your request.

Legal basis. The processing is based on pre-contractual steps taken at your request (Article 6(1)(b) GDPR) and on our legitimate interest in following up on a business enquiry you have initiated (Article 6(1)(f) GDPR).

Storage. The data is stored in the website's own database, hosted on our own server in the European Union. It is not shared with any third party.

Slot booking. The final booking is handled by CloudNess, an internal tool of our company, also self-hosted. The video call takes place on Nextcloud Talk and the calendar invitation is sent to you by email. No external SaaS provider is involved.

Retention. If your request does not lead to a business relationship, your data is deleted no later than 12 months after your last contact with us, unless a longer legal retention obligation applies.

Your rights. You can request access to your data or its deletion at any time by writing to moien@letzagents.lu.

In accordance with the GDPR (EU Regulation 2016/679), each processing activity is based on a legal basis:

All data is hosted on servers located in the European Union (Germany and Finland) at Hetzner Online GmbH, certified ISO 27001.

Our solutions (Umami, appointment booking form, CloudNess) are self-hosted on our own infrastructure. No data passes through US cloud services (no Google, no Amazon, no Microsoft).

Data retention periods are as follows:

• Analytics data (Umami) : retained in aggregated and anonymous form, without time limit (no personal data is involved).
• Appointment booking data : retained for the duration of the business relationship. If the request does not lead to one, the data is deleted no later than 12 months after the last contact, unless a longer legal retention obligation applies.

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

The website letzagents.lu does not use any tracking, advertising or analytics cookies.

Our analytics solution (Umami) works without any cookies. No third-party cookies are stored in your browser during your visit.

Strictly technical cookies may be used by your browser for normal site operation (language preference). These cookies do not collect any personal data and do not require consent under the ePrivacy Directive.