Privacy Policy

Last updated: 24.04.2026

1. Introduction

This Privacy Policy describes how Polls.lu (“App”, “Service”), operated by Polls.lu (“we”, “us”, “our”), processes personal data in accordance with Regulation (EU) 2016/679 (General Data Protection Regulation – GDPR).

We are committed to protecting user privacy while enabling meaningful statistical insights for Luxembourg.

2. Categories of Data Collected

• Account Data: email address, user ID
• Profile Data: demographic information (e.g., age, gender, nationality, residence, education, employment)
• Survey Data: responses, participation data
• Technical Data: device data, IP address, logs
• Usage Data: interaction with the Service

3. Purpose of Processing

We process data for the following purposes:

• Providing and maintaining the Service
• Enabling survey participation and creation
• Generating aggregated statistical insights
• Ensuring integrity, accuracy, and fairness of results
• Preventing abuse, fraud, or manipulation

Profile data is important to improve the statistical relevance and segmentation of survey results.

4. Data Minimization and Use

• We do not sell personal data
• We do not share personal data with third parties for marketing
• We do not use personal data for external advertising
• We use aggregated and anonymized data where possible

5. Data Security and Encryption

We implement appropriate technical and organizational measures in accordance with Article 32 GDPR to protect personal data.

• Data is protected using encryption and secure storage mechanisms
• Access to personal data is restricted to authorized processes and personnel on a need-to-know basis
• We implement safeguards to reduce the risk of unauthorized access, disclosure, or alteration

While we apply strong protection measures, no system can be guaranteed to be completely secure.

6. Data Access and Internal Controls

We are committed to minimizing access to personal data:

• Access is limited and controlled through internal security procedures
• Where possible, data is processed in aggregated or pseudonymized form
• Personnel and developers do not access personal data unless necessary for maintenance, security, or legal obligations

7. Survey Responses and Integrity

Survey responses are processed for statistical purposes only.

• Responses are used in aggregated and non-identifiable form
• We do not use responses to make decisions about individual users

Users must provide honest and accurate answers:

• Deliberate submission of false or misleading responses is prohibited
• Automated or manipulative behavior is strictly prohibited
• Violations may result in suspension or deletion of the account

8. Legal Basis (GDPR)

• Article 6(1)(b) – performance of a contract
• Article 6(1)(f) – legitimate interests (service integrity and improvement)
• Article 6(1)(a) – consent (where applicable)

9. Data Retention

• Unverified accounts may be deleted after 7 days
• Inactive accounts may be deleted after 12 months
• Data is deleted or anonymized when no longer necessary

10. User Rights

Under GDPR, users have the right to:

• Access their data (Article 15)
• Rectify inaccurate data (Article 16)
• Erase data (Article 17)
• Restrict processing (Article 18)
• Data portability (Article 20)
• Object to processing (Article 21)

Requests can be made via contact email. Some requests may be limited by technical or legal constraints.

11. Data Deletion

Users may request deletion of their account and associated data at any time. Deletion is irreversible.

12. Beta Versions Disclaimer

For beta, testing, or pre-release versions of the App:

• All data is considered test data
• Data may be accessible to developers and technical personnel
• Additional logging, monitoring, and debugging processes may be applied
• Users participate in beta versions at their own risk

13. Third-Party Services

We may use infrastructure providers (e.g., hosting, cloud services) under strict data protection agreements. We do not share personal data for marketing or advertising purposes.

14. International Transfers

Data is primarily stored within the European Economic Area (EEA). Any transfer outside the EEA complies with GDPR safeguards (e.g., Standard Contractual Clauses).

15. Children

The Service is not intended for individuals under 18. We do not knowingly collect data from minors.

16. Supervisory Authority

Users have the right to lodge a complaint with:

Commission Nationale pour la Protection des Données (CNPD)
https://cnpd.public.lu

17. Changes

We may update this Privacy Policy. Continued use of the Service constitutes acceptance of updates.

18. Contact

Contact: support@polls.lu