Privacy policy

Controller

The controller is Torus S.à r.l., 144 ZAE Wolser A, L-3225 Bettembourg, Luxembourg. Contact: contact@torus.lu.

Scope of this policy

This policy covers the torus.lu public website. The Torus service is governed by service terms and a data processing agreement entered into with each client.

The public website does not let users create an account, complete a course or run a campaign directly.

Data processed

The public website does not provide user accounts. Messages sent through the contact form are transmitted to Torus by email and are not stored in a database by the website.

The information submitted may include your name, work email, organisation, profile, module of interest and message.

Technical logs may be generated by the hosting provider to ensure security, availability and proper operation of the website.

Audience measurement

The website measures its audience with Umami, hosted by Torus on its own infrastructure: a server it operates at OVHcloud, in France (Gravelines). No third-party audience measurement service is used.

Umami sets no cookie and writes nothing to your browser's storage. The measurement script reads a single value there, “umami.disabled”, which lets you switch measurement off from the browser.

For each page viewed, the following is recorded: the page address (path and URL parameters, including any campaign parameters), its title, the referring site, the screen resolution, the browser language, the browser, the operating system and the device type, the country, region and city inferred from the IP address, and the date and time.

The IP address and the full browser identifier are not recorded as such: together with a random value renewed every month, they are used to compute a session identifier as a hash.

Purpose: measuring the site's traffic — number of visits, pages viewed, referring sources — in order to improve its content. No profiling, no advertising, no tracking of a visitor across sites, no transmission to a third party.

Legal basis: the legitimate interest of Torus in measuring traffic to its website and improving its content (Article 6(1)(f) GDPR). This measurement is carried out by Torus for its own account only, without cookies, without profiling and without any transfer to a third party. You can switch it off from your browser, as described above. You may object at any time.

Retention: audience measurement data is kept for thirteen months at most. An automatic daily purge removes older data.

Purposes

Data sent by email is used to answer contact or demo requests and prepare commercial discussions.

Technical logs are used to protect the website, diagnose incidents and maintain the service.

Recipients and security

Torus does not sell or rent personal data collected through the website.

Data may be accessible to providers needed to operate the website or handle the request, and to competent authorities where required by law.

Torus applies appropriate security measures, including access limitation, separation of uses and technical monitoring of the service.

Cookies

The website uses a functional language preference cookie, named torus_lang, to remember the selected language and help users return to that language after reading resources available in English. It is set for 12 months, is readable by this site only and is accessible to no third party.

This cookie is not used for audience measurement, advertising personalisation or marketing tracking.

The website sets no analytics or marketing cookie. The audience measurement described above works without cookies.

Retention

Emails and related exchanges are kept for the time needed to handle the request and follow up the business relationship.

Technical logs are retained for a limited period by the hosting provider according to its security and operations rules.

Your rights

You may request access, rectification, erasure, restriction, objection or portability of your data where these rights apply.

You can exercise these rights at contact@torus.lu. You may also lodge a complaint with the CNPD in Luxembourg.