Last update : Friday, February 19, 2021
Article 1. Definitions :
The “Visitor” or the “User” : any visitor or Internet user who uses the Website, whether for private or professional purposes, including professionals in the fields of insurance, taxation, accounting, finance, real estate and wealth advice, with professional access to the secure part of the Platform. The User differs from the Visitor by the fact that he has created an account to connect to the Portal.
The “Personal Data” : any information relating to a natural person who is or can be identified, directly or indirectly, by reference to a name, an identification number, or one or more particulars relating to that person, as defined by Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data applicable as of 25 May 2018, including metadata.
The “Cookies” : a cookie is a small data file that can be sent to the Visitor’s and/or User’s browser and stored within his their terminal (e.g. computer, smartphone).
VIREO S.à r.l., as data controller and/or subcontractor (depending on the purpose of use by the connected Users) collects and processes the Personal Data provided by the User on the Website https://www.vireo.lu and the secure portal https://my.vireo.lu (“the Website” and “the Platform”).
The purpose of this Cookie Management Policy is to describe the practices applied in order to respect the privacy of all Visitors and Users of the Website and the Platform.
In the event of any question about the processing of Personal Data on the Website and the Platform, the Visitor and the User may contact VIREO by sending an e-mail to the following address : firstname.lastname@example.org.
Cookies are not used to determine the identity of a person just visiting the Website.
They are used when consulting a product or using the online Platform to track traffic trends in order to determine the location and language preference of a User so that they can be directed to the homepage in the appropriate language when visiting the Website and/or the Platform. These specific cookies are called internal cookies.
An internal cookie file can only be created and viewed by the operator of the website whose page the User visits and thus enables its issuer to identify the web browser on which it is registered, for its entire period of validity. On some pages of the Website and the Platform, Cookies are used to enable the User to keep his or her identifiers and log on automatically.
Third-party Cookies, which are cookies originating from a different domain from that of the Website and/or the Platform, may also be used in the context of advertising and marketing activities.
Article 4. What are the Cookies issued by the Website and the Platform used for ?
Only the issuer of a cookie can read or modify the information it contains. The Cookies used on the Website and the Platform make it possible to identify and remember all of the Visitor’s and/or User’s searches and consultations on the Website and/or the Platform, and more generally to know their behaviour in terms of visits and use.
This information is useful to better personalise the services and content that appear on the Website and/or the Platform and to facilitate browsing. Cookies are also necessary for the proper functioning of certain services or to measure the audience.
When the Visitor and/or User connects to the Website and, mainly, to the Platform, Cookies may be installed on his/their terminal(s), subject to his/their acceptance.
Cookies issued on the Website and the Platform are used for the purposes described below. They result from the parameters of the User’s and Visitor’s browser software used during their visit to the Website and/or the Platform.
Cookies are used to facilitate navigation on the Site and to improve VIREO’s services :
- by adapting the presentation of the Website and/or the Platform to the display preferences of the Visitor’s and/or User’s terminal (language used, display resolution, operating system used, etc.) ;
- by storing information relating to a form that the Visitor and/or User has/have filled in on the Website and/or the Platform (registration or access to the portal account, request for a demo) or to searches, services or information selected on the Website and/or the Platform (search carried out, service subscribed to, content consulted, etc.) ;
- by allowing the Visitor and/or the User to access reserved and personal areas of the Website and/or the Platform, such as the account, thanks to identifiers or data previously entrusted to them ;
- by implementing security measures ;
- by making it possible to establish statistics and volumes of frequentation and use of the various elements making up the Website and/or the Platform (searches, pages and content visited, user path) in order to improve the interest and ergonomics of the VIREO services ;
- by keeping a chat history when the Visitor and/or User contacts the VIREO helpdesk via his chatbox / chatbot.
Article 5. Types of Cookies used
The following Cookies are used on the Site during the navigation of the Visitor and/or the User :
- AspNet.ApplicationCookie – Applicative (session cookie)
- ARRAffinity – Applicative (performance cookie and compatibility with Azure)
- RequestVerificationToken – Applicative (security cookie)
VIREO informs of the purpose of the Cookies of which it is aware and the means available to the Visitor and/or the User to make his/her/their choice of these third party Cookies.
VIREO may include on the Website and the Platform computer applications from third parties. This is the case in particular of the “Share” and “Like” buttons from social networks such as Facebook, Twitter, Linkedin, … The social network providing such an application button is likely to identify the Visitor and/or the User thanks to this button even if they have not clicked on this button during their consultation of the Website and/or the Platform. Indeed, this type of button may enable the social network concerned to track browsing on the Website and/or the Platform, simply because the Visitor’s and/or User’s account giving access to the social network concerned was activated on their terminal(s) (open session) while browsing on the Website.
Article 7. The different possibilities for managing Cookies
The choices available on the browser are :
- the configuration of the browser so that cookies are saved in the terminal or, on the contrary, that they are rejected, either systematically or according to the sender ;
- the configuration of the browser so that the acceptance or refusal of cookies is proposed punctually before a cookie can be saved on the terminal.
For the management of Cookies and the choices of the Visitor and the User, the configuration of each browser is different. It is described in the browser’s Help menu. The latter allows you to find out how to change your cookie preferences.
Article 8. The agreement on Cookies
The registration of a Cookie in a Terminal is subject to the will of the Visitor and/or the User of the Terminal, which the Visitor and/or User may express and modify at any time, free of charge, through the choices offered by the browser.
If the Visitor and the User have accepted the recording of cookies in their browser software, the cookies incorporated in the pages and content consulted may be temporarily stored in a dedicated space on their terminal. They will only be readable by their transmitter.
Article 9. Refusal of Cookies and the consequences
If the Visitor and/or User refuses to accept the registration of Cookies in his/her/their terminal(s) or if he/she/they delete the Cookies registered there, he/she/they will no longer be able to benefit from a certain number of functionalities required to access certain areas of the Website and/or the Platform, in particular content or services that require identification, language settings or display.
Where applicable, VIREO declines all responsibility for the consequences related to the degraded functioning of its services resulting from the impossibility to record or consult the Cookies necessary for their proper functioning and which the Visitor and/or User would have refused or deleted.
With regard to audience measurement cookies in particular, the Visitor and the User may also deactivate them as follows.
- For more information on how to set cookies : http://www.aboutcookies.org/
- For “Google Analytics” cookies, it is possible to download the module accessible from the following address to deactivate them : https://tools.google.com/dlpage/gaoptout
- For Internet Explorer™: https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies?ocid=IE10_about_cookie
- For Safari™: http://support.apple.com/kb/HT1677?viewlocale=en_US
- For Chrome™: https://support.google.com/chrome/answer/95647?hl=e
- For Firefox™: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preference
- For Opera™: http://help.opera.com/Windows/10.20/en/cookies.html.
For more information concerning Cookies and more broadly on the rights and duties of the Visitor and the User with regard to the use of his/her personal data, VIREO invites you to consult the law of July 28, 2011 concerning Internet connection “cookies” and its/their guarantees of transparency and fair use of these techniques.
Further questions may be communicated to email@example.com with the heading : “User cookies”.