PRIVACY POLICY
This document details the personal data protection policy applied to the privacyelite.com website.
1. Who we are (data controller)
This website is operated by the European Centre for Certification and Privacy (ECCP).
- Address: 22, Boulevard des Scillas, L-2529 Howald, Luxembourg
- Website: https://eccpcenter.org
- Contact, including for privacy related questions: through the eccpcenter.org contact form
If you have any question about this policy or about how your personal data is handled on this site, please contact us using the details above.
2. Personal data processing and purpose
2.1 Technical access data (server logs)
Like any website, our hosting infrastructure automatically records limited technical data each time a page or asset is requested. This is necessary to enable your browser to remotely access our webserver, as well as to maintain the website service and to keep it secure and available.
| Data | IP address, date and time of the request, the page or file requested, HTTP status, referring URL, and browser/operating-system information (user agent) |
|---|---|
| Purpose | Delivering the website, ensuring network and information security, detecting and preventing abuse, and maintaining technical stability |
| Legal basis | Legitimate interests, Article 6(1)(f) GDPR (operating a secure and functional website) |
| Retention | Retention period is determined by the need to keep a benchmark profile of regular access enabling to identify any suspicious deviation, as well as to retrospectively check and analyse any attempt to attack the service. |
| Provided by you? | This data is generated automatically by your computer or mobile phone when connecting to our webserver as a technical necessity to establish an internet connection. It is not something you actively provide. |
2.2 Embedded videos (Vimeo)
The site displays videos that are hosted by Vimeo (Vimeo.com, Inc., United States). To protect your privacy, these videos are loaded using a click-to-play approach: nothing is requested from Vimeo, and no Vimeo cookies are set, when the page simply loads.
Only if you actively click play on a video, your browser then connects to Vimeo to stream it. At that point:
- Vimeo receives your IP address, technical device and browser information, and data about the video you are watching;
- Vimeo may set its own (third-party) cookies or use similar technologies on your device, in line with Vimeo's own policies;
- this data is processed by Vimeo as an independent controller for its own purposes, over which we have no control.
| Trigger | Only when you click play on a video (no processing on page load) |
|---|---|
| Data shared with Vimeo | IP address, device/browser data, video viewing data, and any identifiers Vimeo sets |
| Purpose | Enabling you to watch the embedded videos |
| Legal basis | Your consent, expressed by the deliberate act of clicking play after being informed (Article 6(1)(a) GDPR); you are free not to click |
| Vimeo's processing | Governed by Vimeo's own privacy and cookie policies: https://vimeo.com/privacy and https://vimeo.com/cookie_policy |
You can avoid all Vimeo processing simply by not clicking play on the videos.
2.3 No analytics, advertising, or profiling
We do not use web analytics, advertising cookies, social-media trackers, tag managers, or profiling tools on this site. We do not carry out any automated decision-making producing legal or similarly significant effects within the meaning of Article 22 GDPR.
3. Cookies and similar technologies
This website does not use cookies. However, it provides access to video files that are hosted by a service provider who may use cookies when clicking on the links to open and display video recording (see section 2.2).
Because no cookies are placed on load and the video cookies are set solely as a result of your own deliberate action after a clear notice, the site operates without a consent banner. The exact cookies Vimeo uses are determined by Vimeo and are listed in Vimeo's cookie policy (linked above); a commonly set example is Vimeo's vuid cookie used for video playback statistics.
You can manage or block cookies at any time through your browser settings. Blocking third-party cookies may affect video playback but will not affect the rest of the site.
4. Third parties (recipients)
We do not sell any personal personal data and do not use them for marketing purposes. Stored data may be processed by our web hosting technical service providers, including: Infomaniak, Mandat Interantional, and IoT Lab. We also use a third-party service provider for hosting the video files displayed on the webpage: Vimeo.com, Inc., which is an independent controller, which is interacting with your browser when you choose to play an embedded video (section 3.2).
5. International data transfers
Server logs and hosting of the website pages are kept within the EU/EEA and Switzerland.
When you choose to play a video, the resulting processing by Vimeo (Vimeo.com, Inc., a US company) may involve sharing your IP address with servers located in the United States. According to Vimeo's Privacy Policy (last updated 19 September 2025), Vimeo relies on the following safeguards for such transfers:
- the EU-U.S. Data Privacy Framework (DPF) (and the UK Extension and Swiss-U.S. DPF): Vimeo is self-certified under the DPF and adheres to the DPF Principles (see the official DPF list at www.dataprivacyframework.gov);
- the EU Standard Contractual Clauses ("Model Clauses"), applied where appropriate as a complementary safeguard.
Vimeo's representative in the EU/EEA is the European Data Protection Office (EDPO), Avenue Huart Hamoir 71, 1030 Brussels, Belgium. Full details are in Vimeo's Privacy Policy (linked in section 2.2).
6. How long we keep your data
- ECCP server access logs: Retention period is determined by the need to keep a benchmark profile of regular access enabling to identify any suspicious deviation, as well as to retrospectively check and analyse any attempt to attack the service.
- Vimeo data: retained by Vimeo according to Vimeo's own retention policies; we hold no copy.
We keep no other personal data from your visit, because none is collected.
7. Your rights
Under the GDPR you have the right to:
- access the personal data we hold about you (Article 15);
- request rectification of inaccurate data (Article 16);
- request erasure (Article 17);
- request restriction of processing (Article 18);
- data portability (Article 20), where applicable;
- object to processing based on our legitimate interests (Article 21);
- withdraw consent at any time, where processing is based on consent, without affecting the lawfulness of processing before withdrawal (for the videos, you withdraw simply by not playing them and by clearing any Vimeo cookies in your browser).
To exercise any of these rights, contact us through our online contact form.
You also have the right to lodge a complaint with a supervisory authority. As the controller is established in Luxembourg, the competent authority is the Commission nationale pour la protection des données (CNPD). You may also complain to the supervisory authority in your own EU or EEA country of residence.
8. Changes to this policy
This policy is subject to changes that will be published online. The applicable rules are those of the published policy.