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privacy policy

Last Updated: March 19, 2025

At aigentcy, a brand owned by Cimomedia S.á r.l. (hereinafter “Cimomedia,” “we,” “us,” or “our”), we are committed to protecting your privacy and ensuring the security of your personal data in compliance with the General Data Protection Regulation (GDPR) and applicable Luxembourg laws. This Privacy Policy explains how we collect, use, store, and protect your personal information, as well as your rights regarding your data. If you have questions, please contact us at privacy@aigentcy.lu or at our registered address: Cimomedia S.á r.l., 44, rue de Wiltz, L-2734 Luxembourg, Luxembourg.

1. Data Controller

Cimomedia S.á r.l. is the data controller responsible for processing your personal data under the aigentcy brand. We determine the purposes and means of processing as outlined below.

2. Personal Data We Collect

We collect and process the following types of personal data depending on how you interact with our website and services:
 

  • Data You Provide Directly:

    • Community Application: When you apply to join our community, we collect your name, email address, and any additional information you voluntarily submit via the form (e.g., comments or preferences).

    • Contact Requests: If you reach out via email or phone, we process the details you provide (e.g., name, contact information, message content).
       

  • Data Collected Automatically:

    • Website Usage Data: We may collect technical information such as your IP address, browser type, operating system, referring URLs, and pages visited through cookies or similar technologies (see Section 8: Cookies).

    • Analytics: If enabled, tools like Google Analytics may collect anonymized data about your browsing behavior to improve our site.
       

  • Data from Third Parties:

    • Community Platform: When you join our community via Skool, we may receive data you provide there (e.g., profile information), subject to Skool’s privacy terms.

3. Purposes of Processing

​We process your personal data for the following purposes:
 

  • To process and respond to your community application or inquiries.

  • To provide access to and manage our community platform in collaboration with Skool.

  • To communicate with you, including sending updates or service-related notifications.

  • To improve our website, services, and user experience through analytics (if applicable).

  • To comply with legal obligations, such as tax or regulatory requirements in Luxembourg.

4. Legal Basis for Processing

We process your data based on one or more of the following GDPR legal bases:
 

  • Consent (Art. 6(1)(a)): When you agree to data processing (e.g., via the community form or cookie banner).

  • Contract (Art. 6(1)(b)): To fulfill our obligations to you (e.g., providing community access).

  • Legitimate Interest (Art. 6(1)(f)): For purposes like website optimization or security, balanced against your rights.

  • Legal Obligation (Art. 6(1)(c)): To meet regulatory requirements.

5. Data Storage and Retention

  • ​Location: Your data is stored on secure servers within the European Union, primarily in Luxembourg, ensuring GDPR compliance.

  • Duration: We retain your data only as long as necessary:

    • Community form data: Until your application is processed or membership ends, unless longer retention is legally required.

    • Contact inquiries: For 12 months after resolution, unless further action is needed.

    • Analytics data: Up to 26 months (if applicable), then anonymized.

    • Legal obligations: As required by Luxembourg law (e.g., tax records for 10 years).

  • Deletion: Data no longer needed is securely deleted or anonymized.

6. Data Sharing and Third Parties

We may share your data with the following recipients under strict safeguards:
 

  • Service Providers: Trusted partners like Skool (community platform) or hosting providers, bound by data processing agreements (DPAs) compliant with GDPR.

  • External Tools: If we use analytics (e.g., Google Analytics) or marketing tools, data may be shared with providers outside the EU (e.g., USA), subject to Standard Contractual Clauses (SCCs) or equivalent safeguards.

  • Legal Authorities: If required by law or to protect our rights, we may disclose data to regulators or courts.

    Please note: We do not sell or rent your personal data to third parties.

7. Your Rights

​Under GDPR, you have the following rights regarding your personal data:
 

  • Access: Request a copy of the data we hold about you.

  • Rectification: Correct inaccurate or incomplete data.

  • Erasure: Ask us to delete your data (“right to be forgotten”), unless we must retain it for legal reasons.

  • Restriction: Limit how we process your data in certain cases.

  • Data Portability: Receive your data in a structured, machine-readable format.

  • Objection: Object to processing based on legitimate interests (e.g., analytics).

  • Withdraw Consent: Revoke consent at any time, without affecting prior processing.


To exercise these rights, contact us at privacy@aigentcy.lu. We will respond within one month, extendable by two months for complex requests. If dissatisfied, you may lodge a complaint with the Luxembourg National Commission for Data Protection (CNPD) at https://cnpd.public.lu.

8. Cookies and Tracking Technologies

​Our website may use cookies or similar technologies to enhance functionality and analyze usage. Categories include:
 

  • Essential Cookies: Necessary for site operation (e.g., navigation).

  • Analytics Cookies: To understand how visitors use our site (optional, with consent).

  • Third-Party Cookies: From tools like Skool or Google (if applicable).
     

You can manage preferences via our cookie banner or your browser settings. Rejecting non-essential cookies won’t affect core functionality.

9. Data Security

​We implement technical and organizational measures to protect your data, including:
 

  • Encryption of data in transit (HTTPS) and at rest.

  • Access controls and employee training.

  • Regular security reviews of our systems and third-party providers.

 

In the unlikely event of a data breach, we will notify you and the CNPD within 72 hours if there’s a risk to your rights.

10. International Data Transfers

​If data is transferred outside the EU (e.g., via Skool or US-based tools), we ensure compliance through:
 

  • Standard Contractual Clauses (SCCs) approved by the European Commission.

  • Verification of third-party privacy frameworks (e.g., Data Privacy Framework, if applicable).

11. Changes to This Policy

​We may update this Privacy Policy to reflect legal or operational changes. Significant updates will be communicated via email or a website notice. Check the “Last Updated” date for the latest version.

12. Contact Us

For questions, requests, or concerns about your data, reach out to:

Cimomedia S.á r.l. (aigentcy)
Email: privacy@aigentcy.lu
Phone: +352 661 88 99 55
Address: 44, rue de Wiltz, L-2734 Luxembourg, Luxembourg


For complaints, you may also contact the CNPD:
Commission nationale pour la protection des données
Website: https://cnpd.public.lu
Address: 15, Boulevard du Jazz, L-4370 Belvaux, Luxembourg

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