1. Joint Controllers
The following companies are Joint Controllers for all processing of personal data in accordance with Art. 4 (7) of the EU General Data Protection Regulation (GDPR) and Art. 26 of the GDPR:
• Outlet Mall Messancy SRL, Rue d'Arlon 199, 6780 Messancy
E-mail: info@designeroutletluxembourg.com
• ROS Belgium Management SRL, Avenue du Boulevard 21 Box 8, 1210 Saint-Josse-ten-Noode, E-mail: info@designeroutletluxembourg.com,
Tel: +32 (0) 63 23 00 40
hereinafter referred to as "data controllers".
Being Joint Controllers means that each of the data controllers process your data jointly, taking into account the highest data protection standards. A corresponding contract has been concluded between each of the data controllers. Even if there is joint responsibility, the data controllers fulfil the obligations under data protection law in accordance with their respective responsibilities. Within the framework of joint responsibility, you can assert your rights in connection with data processing with each of the data controllers. Primarily, kindly direct your concerns and inquiries to ROS Belgium Management SRL, Avenue du Boulevard 21 Box 8, 1210 Saint-Josse-ten-Noode, E-mail: info@designeroutletluxembourg.com, Tel: +32 (0) 63 23 00 40
Furthermore, the company has appointed an external Data Protection Officer who can be contacted at the following email address: datenschutz-ros@meineberater.at.
2. General Data processing
2.1 Data processing in accordance with Art 13 GDPR
We process the data that data subjects provide to us, for example in the context of an enquiry by E-Mail, for the purpose of initiating and concluding a contract or a business relationship.
2.2 Data processing in accordance with Art 14 GDPR
In addition, we process data of persons who may be part of a contractual relationship, which we have permissibly received in the context of information provided by third parties (e.g., managing directors provide us with the data of their employees or colleagues).
2.3 Data Subjects
We process the following data from contracting parties (e.g. VIP Club members, competition participants): first and last name, E-Mail address, date of birth.
We process the following data from contact persons of tenants: Company, title and name of contact person, business address data and contact data, bank details, contract data.
We process the following data from suppliers and business partners that is required for the initiation or conclusion of a contract: Company, title and names of contact persons, business address data and contact data, bank details, contract data.
We process the following data from event participants: Name, contact data and address data.
2.4 Recipients of personal data
Recipients of personal data will only be third parties if it is necessary for the fulfilling of a contract or if it is required by law.
2.5 Data retention/Deletion
- Expiration of contractual obligations: If there are contractual provisions that prescribe how long personal data must be retained, the data controller ensures that these deadlines are met. Once these deadlines have expired, the data is deleted or anonymized by the data controller.
- Withdrawal of consent: If a person withdraws consent to the processing of their personal data, the data controller deletes this data unless there is another legal basis for processing.
- Expiration of legal obligations: In some cases, there may be exceptions that not only allow but even require the data controller to continue retaining personal data for a defined period, such as the storage of tax or accounting records. After these statutory deadlines have expired, the data controller also ensures that the data is anonymized or deleted.
2.6 Contact by E-mail
When you contact us via email, the data you provide will be stored by us in order to respond to your inquiries. We will delete this data once it is no longer necessary for processing or restrict the processing if legal retention periods apply.
Legal basis: Art. 6 para. 1 lit. f GDPR
2.7 Publication of the names of originators
We are required by law to disclose names of creators of image data (photos or videos) whenever we publish image data. We automatically delete this personal data as soon as we stop using the image data.
2.8 Legal basis
The below points are the legal basis of data processing:
- Initiation and fulfilment of the contract in accordance with Art. 6 para. 1 lit. b GDPR.
- Legal obligations in accordance with Art. 6 para. 1 lit. c GDPR, (for example, legally prescribed storage and documentation obligations).
- Legitimate interests of our company within the meaning of Art. 6 para. 1 lit. f GDPR (for example usage of software).
- Art 6 para. 1 lit. a GDPR when obtaining consent (for example when processing image data or for advertising purposes).
3. Data processing of VIP Club members
If you decide to become a member of our VIP Club, we will process the data you enter in our form (online or print).
A membership in our VIP Club with many financial advantages requires the authorisation of the Outlet to send you offers, information, advertising, invitations to competitions as well as promotions of the partners of the designer outlet by E-Mail.
In order to complete your registration in the VIP Club, we require your first and last name as well as a valid E-Mail address or a further confirmation that you are indeed the supposed recipient of the mailings sent to you. For this purpose, we will send a confirmation E-Mail to the E-Mail address entered with a link contained therein (double opt-in); only after clicking on this link is the registration completed.
If you want to receive special birthday vouchers as a member of the VIP Club, we also need your date of birth. However, you can also become a member without mentioning your date of birth. For this purpose of processing, the legal basis utilized is our legitimate interest in providing the client with a personalized service.
We collect further data in this context insofar as you provide it, but this is not necessary for the receipt of the advertisements.
If you do not wish to receive any more mailings, you can terminate your membership at any time informally by sending an E-Mail to the contact details given in section one of this Privacy Policy. When you terminate your membership, we will immediately delete your personal data processed for this purpose.
When you become a member of our VIP Club, you enter into a contract with us in that you receive discounts and we process your data in return. The processing of your data is thus necessary for the performance of the contract to which you are party.
Legal basis: Art. 6 para. 1 lit. b GDPR
4. Data processing of competition participants
If you take part in our competitions, we will process your data in order to carry out the competition, to determine and notify the winner and to send the prize offered. For this purpose, we need to process your name and your E-Mail address. Without this data, you cannot participate in the competition. As participants must be at least 18 years old in order to enter the competition, you also need to provide your date of birth.
You can also disclose your telephone number on a voluntary basis. If you do so, we will use this data to contact you by telephone if you have not responded to the E-Mail prize notification. However, this data is not necessary for entering the competition. We process this personal data based on our legitimate interest in providing the winner with the respective prize.
The data will be deleted after the winner has been determined and the competition has been completed.
When you enter our competition, you enter into a contract with us, in that you get the chance to win a prize, while we process your data in return. The processing of your data is thus necessary for the performance of the contract to which you are party.
Legal basis: Art. 6 para. 1 lit. b GDPR
5. Data processing via our website
5.1 Contact
If you have asked us to contact you via our web form or if you have sent us a message, we store the data that is required to contact you. This is your name and your E-Mail address. We additionally process data that you provide to us voluntarily. We delete the data as soon as storage is no longer necessary or you object to the processing. The processing of your data for this purpose is based on our legitimate interest in replying to our client’s inquiries and questions.
Legal basis: Art. 6 para. 1 lit. f GDPR
5.2 Applicants
If you send us your application documents, we process your personal data contained therein as well as your CV and references for the purpose of personnel selection and filling the position. The processing of your data is necessary to take steps at your request prior to entering into a contract with you. In the event of a rejection, we delete your documents 7 months after sending the rejection to you.
Legal basis: Art. 6 para. 1 lit. b GDPR
If you consent to be kept on file with us for the purpose of contacting you later, we will approach you with a separate request for the transmission of a consent. If you explicitly give us this consent, we will store your consent. If there is no further opportunity to fill a vacancy with us within one year, we will delete all your applicant data one year after you have sent us your consent.
Legal basis: Art. 6 para. 1 lit. a GDPR
6. Data processing when visiting our website
6.1 Informative use of the website
In the case of informative use of the website, we only collect the personal data that your browser transmits to our server (server log files). If you wish to view our website, the most data we collect is that which is technically necessary for us to display our website to you and to ensure its stability and security:
- IP address
- Date and time of the request
- Time zone difference to Coordinated Universal Time (UTC)
- Content of the request (specific page)
- Access status/HTTP status code
- Website from which the request came
- browser
- Operating system and its interface
- Language and version of the browser software.
This data is not merged with personal data sources. We reserve the right to check this data retrospectively if we become aware of concrete indications of unlawful use and to pass on the data to the law enforcement authorities if there has been a hack attack. The data will not be passed on to third parties beyond this.
Legal basis: Art. 6 para. 1 lit. f GDPR
6.2 Cookies
Cookies are stored on your computer when you use our website. Cookies are small text files that are stored on your hard drive in relation to the browser you are using and which provide the party setting the cookie (in this case us) with certain information. Cookies cannot execute programs or transmit viruses to your computer.
The cookie enables you to be recognised when you visit the website without having to re-enter data that you have already entered previously.
The information contained in the cookies is used, for example, to determine whether you are logged in or which data you have already entered, or to recognise you as a user when a connection is established between our web server and your browser.
We distinguish between technical cookies, which are used exclusively to ensure the operation of a website, and other cookies, which are set for the purpose of statistical analysis, tracking or advertising/marketing by us or third-party providers.
Details of our cookies
Legal basis: Art. 6 para. 1 lit. f GDPR (in the case of technical cookies), Art. 6 para. 1 lit. a GDPR (for all other cookies)
7. Social Media
We operate the social media sites: Facebook and Instagram. When visiting our social media pages, personal data, including the IP address, is processed by the respective provider and cookies are used for data collection. For detailed information on the specific data transmitted, please refer to the privacy policy of each service. There, you will also find contact information and various privacy settings.
We prioritize comprehensive customer satisfaction and primarily use these services to engage and communicate with you.
In services with a US connection, the data collected is usually transmitted to a server in the USA and stored there. We have no control or ability to supervise the nature or extent of the data processed by these services, the way it is processed and used or the disclosure of this data to third parties. To limit the processing of this data within the settings of these services, please refer to the detailed descriptions provided in the privacy policies of the respective providers.
Furthermore, we point out that you use the respective services and their features at your own responsibility. This applies particularly to the use of interactive functions such as sharing, commenting, or rating.
The providers of the social media services have provided us with corresponding agreements - in most cases these are agreements on joint responsibility for data processing. The use of social media is based on our legitimate, operational interest.
Legal basis: Art. 6 para. 1 lit. f GDP
8. Cloud.Typography
Our website uses external fonts from Hoefler & Co, 611 Broadway, Room 725, New York, NY 10012-2608, USA.
This service provides the "Cloud.Typography" fonts, which are displayed on users' end devices. In each session, your browser establishes a direct connection with the company's servers in the USA, whereby your IP address can be retrieved.
For more information, please see Typography's privacy policy:
https://www.typography.com/policies/privacy
With this service, a transfer of personal data to the USA cannot be excluded! The GDPR requires appropriate safeguards under Article 46 GDPR for any data transfers to a third country or international organization. Such guarantees do not exist for the USA.
Furthermore Hoefler & Co. has at the current time not certified itself under the US Data Privacy Framework or the Privacy Shield. For this reason certain risks cannot be entirely ruled out for you as data subjects. These risks include:
- Your personal data may be shared with other third parties (e.g.: US authorities) by the respective service provider.
- You may not be able to sustainably assert or enforce your rights of access against the respective service provider.
- There may be a higher probability of incorrect data processing because the technical organizational measures for the protection of personal data do not fully comply with the requirements of the GDPR in terms of quantity and quality.
Legal basis: Art. 6 para. 1 lit. a GDPR
9. Facebook
9.1 Facebook Pixel
Our website uses Facebook pixels ("Pixel") of the social network Facebook (Meta Platforms Ireland Ltd., 4 Grand Canal Square Grand Canal Harbour, Dublin 2, Ireland) for the analysis, optimisation and economic operation of our online offer.
Facebook can use the pixels to determine the website visitors as a target group for the display of advertisements (so-called "Facebook ads"). Accordingly, we use them to display the Facebook ads placed by us only to those Facebook users who have also shown interest in our online offer or who have certain characteristics (e.g., interests in certain topics or products determined based on the websites visited) that we transmit to Facebook (so-called "Custom Audiences"). The aim is to ensure that our Facebook ads correspond to user interest and do not have a harassing effect. On the other hand, we can use pixels to track the effectiveness of Facebook ads for statistical and market research purposes by seeing whether users were redirected to our website after clicking on a Facebook ad (so-called "conversion").
Your actions are stored in one or more cookies. These cookies allow Facebook to match your user data (such as IP address, user ID) with your Facebook account data. The data that is collected is anonymous and not visible to us and can only be used in the context of advertisements. If you would like to prevent the linking with your Facebook account, you have the option to log out before taking any action.
We have entered into a contract with Facebook Ireland, nevertheless it may happen that Facebook Ireland transfers personal data to Facebook USA. Meta Platforms, Inc. has certified itself under the EU-U.S. Data Privacy Framework for the transfer of personal data from the EU to the United States. The European Commission has determined that there is an adequate level of protection for personal data transferred from the EU to a company in the United States certified under the EU-U.S. Data Privacy Framework. Consequently, the data transfer is permissible in accordance with Article 45 of the GDPR.
For further information, please refer to Facebook's data policy at https://en-gb.facebook.com/policy.php
For specific information on Facebook Pixels, please refer to https://en-gb.facebook.com/business/help/742478679120153?id=1205376682832142.
Legal basis: Art. 6 para. 1 lit. a GDPR
10. Google Services
We have signed a contract with Google Ireland Limited ("Google"), a company incorporated and operated under the laws of Ireland (registration number: 368047) with its registered office at Gordon House, Barrow Street, Dublin 4, Ireland. Nevertheless, it may happen that data is transmitted from Europe to the USA, over which we as a company have no influence.
Google has certified itself under the EU-U.S. Data Privacy Framework for the transfer of personal data from the EU to the United States. The European Commission has determined that there is an adequate level of protection for personal data transferred from the EU to a company in the United States certified under the EU-U.S. Data Privacy Framework. Consequently, the data transfer is permissible in accordance with Article 45 of the GDPR.
Legal basis: Art 6 para 1 lit a GDPR
10.1 Google Analytics
We have integrated Google Analytics on our website, a web analysis service from Google, which enables us to analyse visitor flows and the length of stay on our website.
This website uses the function "Activation of IP anonymization" (i.e. Google Analytics has been extended by the code "gat._anonymize Ip();" to ensure anonymized collection of IP addresses (so-called IP masking)). This means that your IP address is shortened beforehand by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there.
According to Google, Google will use the information obtained to evaluate your use of the website, to compile reports on website activity and to provide us with other services related to website and internet use. The IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data. Google may, however, transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. You can prevent the storage of cookies by setting your browser software accordingly. However, we would like to point out that in this case you may not be able to use all the functions of the website to their full extent. Furthermore, you can prevent the collection of the data generated by the cookie and related to your use of the websites (including your anonymized IP address) by Google as well as the processing of this data by Google by downloading and installing the browser plug-in available under the following link (https://tools.google.com/dlpage/gaoptout?hl=en).
For more information on the terms of use and data protection, please visit https://marketingplatform.google.com/about/analytics/terms/us/ or https://support.google.com/analytics/answer/6004245?hl=en.
10.2 Google Analytics Conversion Tracking (Google Ads)
This website also uses Google Conversion Tracking. Google Ads sets a cookie on your computer if you have accessed our website via a Google advertisement. These cookies lose their validity after 30 days and are not used for personal identification. If the user visits certain pages of the Ads client's website and the cookie has not yet expired, Google and the client can recognize that the user clicked on the ad and was redirected to that page. Each Ads client receives a different cookie. Cookies can therefore not be tracked across Ads clients' websites. The information obtained using the conversion cookie is used to create conversion statistics for Ads clients who have opted into conversion tracking. Ads clients learn the total number of users who clicked on their ad and were redirected to a page tagged with a conversion tracking tag. However, they do not receive any information that personally identifies users. If you do not wish to participate in the tracking procedure, you can also refuse the setting of a cookie required for this - for example, via a browser setting that generally deactivates the automatic setting of cookies. You can also deactivate cookies for conversion tracking by setting your browser so that cookies from the domain "www.googleadservices.com" are blocked. Google's privacy policy can be found here.
When you use SSL search, Google's encrypted search feature, the search terms are usually not sent as part of the URL in the referring URL. However, there are some exceptions to this, for example if you are using certain fewer common browsers. For more information on SSL search, click here. Search queries or information in the referral URL could also be viewed through Google Analytics or an application programming interface (API). In addition, advertisers may receive information about the exact search terms that triggered a click on an ad. https://policies.google.com/faq?hl=en
10.3 Google Doubleclick
The website uses the online marketing tool DoubleClick. To help AdWords customers and publishers serve and manage ads on the web, the Google advertising network and certain Google services may be used. DoubleClick uses cookies to serve ads that are relevant to users, to improve campaign performance reports, or to prevent a user from seeing the same ads more than once. Google uses a cookie ID to record which ads are shown in which browser and can thus prevent them from being shown more than once. In addition, DoubleClick can use cookie IDs to record so-called conversions that are related to ad requests. This is the case, for example, when a user sees a DoubleClick ad and later calls up the advertiser's website with the same browser and buys something there. According to Google, DoubleClick cookies do not contain any personal information. Due to the marketing tools used, your browser automatically establishes a direct connection with Google's server. We have no influence on the scope and further use of the data collected by Google using this tool and therefore inform you according to our state of knowledge: Through the integration of DoubleClick, Google receives the information that you have called up the corresponding part of our website or clicked on an advertisement from us. If you are registered with a Google service, Google can assign the visit to your account. Even if you are not registered with Google or have not logged in, it is possible that the provider may obtain and store your IP address.
10.4 Google Fonts
We use Google Fonts on our Website. To ensure a uniform and appealing display of the fonts and icons, your browser loads the required fonts into your browser cache. To do this, it is necessary for the browser you are using to contact the Google Fonts servers, which results in Google Fonts becoming aware that our website has been accessed via your IP address.
You can find out what data is collected by Google and what it is used for at https://policies.google.com/privacy?hl=en
10.5 Google Maps
On this website, we use the Google Maps service. This allows us to show you interactive maps directly on the website and enables you to use the map function conveniently. By visiting the website, Google receives the information that you have called up the corresponding sub-page of our website. In addition, the data already mentioned under the point "Informational use of the website" will be transmitted. This occurs regardless of whether Google provides a user account via which you are logged in or whether no user account exists. If you are logged in to Google, your data will be directly assigned to your account. If you do not want your data to be associated with your Google profile, you must log out before activating the button. Google stores your data as usage profiles and uses them for the purposes of advertising, market research and/or designing its website in line with requirements. Such an evaluation is carried out in particular (even for users who are not logged in) to provide needs-based advertising and to inform other users of the social network about your activities on our website. You have the right to object to the creation of these user profiles, and you must contact Google to exercise this right.
For more information on the purpose and scope of data collection and processing by the plug-in provider, please refer to the provider's privacy policy. There you will also find further information on your rights in this regard and setting options for protecting your privacy: https://policies.google.com/privacy?hl=en&gl=en.
10.6 Google ReCAPTCHA
We use Google's ReCAPTCHA service to determine whether a human or computer is making a particular entry in our contact or newsletter form. Google uses the following data to check whether you are a human or a computer: IP address of the terminal device used, the website you visit with us on which the captcha is embedded, the date and duration of the visit, the recognition data of the browser and operating system type used, Google account if you are logged in to Google, mouse movements on the ReCAPTCHA areas and tasks that require you to identify images.
10.7 Google Tag Manager
We use Google Tag Manager to recognise your user behaviour. The Google Tag Manager is a solution with which marketers can manage website tags via an interface. The tool itself processes the following personal data: IP address of the user. The tool triggers other tags, which in turn may collect data. Google Tag Manager does not access this data. The Google Tag Manager can set cookies, at least in the preview and debug mode of the administrator, but also outside of it. If a deactivation has been made at domain or cookie level, this remains in place for all tracking tags implemented with Google Tag Manager.
More detailed information is available here: https://support.google.com/tagmanager/?hl=en#topic=3441530
11. Your rights
You have the following rights in relation to personal data relating to you:
- Right of access, right to rectification and erasure
- Right to restriction of processing
- Right to object to processing
- Right to data portability
Please direct your enquiries and requests by E-Mail to info@designeroutletluxembourg.com or contact us using the contact details provided.
If you believe that we have violated Luxembourgish or European data protection law in the processing of your data and have thereby infringed your rights, please contact us so that we can clarify any issues.
You also have the right to complain to the supervisory authority, which is the Luxembourgish Data Protection Authority:
National Comission for Data Protection, Grand-Duchy Luxembourg
15, Boulevard du Jazz
L-4370 Belvaux
Telefon: (+352) 26 10 60 -1
Fax.: (+352) 26 10 60 29
E-Mail: plaintes@cnpd.lu
Homepage: https://cnpd.public.lu
12. Changes to this Privacy Policy
We reserve the right to modify this Privacy Policy at any time. Changes to this Privacy Policy will be published by us on this page. Please refer to the current version of our Privacy Policy in this regard.
