Privacy Policy

1 Introduction

This Privacy Policy is provided to you in order to explain the policy of the Joint Allocation Office (JAO) SA ("the Company" or "JAO") regarding your privacy as well as how your personal information is handled. In collecting this information, the Company is acting as a data controller and, by law, it is required to provide you with information about the Company, about why and how JAO is using your data, and about the rights you have over your data.

1.1 Who are we?

We are the Joint Allocation Office (JAO) SA. Our address is 2 rue de Bitbourg, Hamm-Luxembourg, L-1273. You can contact us by post at the above address, by email at contact@jao.eu or by telephone on +352 27 62 38 01.

Any enquiries about our use of your personal data should be addressed by email at gdpr@jao.eu. 

2 How we use your information

When you use our website to browse our services and view the information we make available, a number of cookies are used by us and by third parties to allow the website to function. Some of the cookies we use are strictly necessary for our website to function, as well as cookies that are strictly necessary to provide an online service that you explicitly requested (i.e. creating a user account for publication of information on our website's Message Board). For these cookies, we do not ask for your consent.

However, for cookies that are useful but not strictly necessary - such as analytics or behavioural insight tools - we will always ask for your consent before placing them. These include Google Analytics and Crazy Egg, which help us understand how visitors use our website and improve the user experience. These cookies will only be activated if you have provided your prior consent through our cookie banner.

2.2 When you submit an enquiry via our website

When you submit an enquiry via our website, we ask you for your email address.

We use this information to respond to your query, including providing you with any requested information about our services. We may also email you several times after your enquiry in order to follow up on your request and ensure that we have answered to your satisfaction. We will do this based on our legitimate interest in providing accurate information.

We do not use the information you provide to make automated decisions that might affect you.

2.3 When you submit an enquiry via our service desk

When you submit an enquiry via our service desk, we ask you for your name and your corporate email address.

The use of the service desk platform requires a registration for the creation of a user account following the instructions of the user guide available in our website. 

The service desk platform is only used for the purpose of facilitating raised requests by existing and potential clients in relation to services provided by JAO. The notification system informs the registered accounts through an electronic message about every new additional registered user of the same company (client).

We do not use the information you provide to make automated decisions that might affect you.

2.4 When you register to participate in auctions

When you register to participate in auctions held by JAO, you are required to provide certain information and documentation. All relevant documents and forms requested for the registration are available on this website under the "Documents" tab > "Resource center" in the "Registration" section.

The information and documentation required is in accordance with the Harmonised Allocation Rules ("HAR").

We will use your information for identification, verification and notification purposes in accordance with our obligation to assess the completeness of information submitted by you under Article 9 and Article 13 of the HAR and to ensure that you fulfil your obligations as specified in the HAR to participate in auctions.

We require this information in order to provide our services as stated under the relevant Participation Agreement and Financial Agreement.

Your information is stored on our server, which is based within the European Union. Your bank details are shared with our banking partner who is based in Luxembourg and with whom we have a contractual agreement which provides effective safeguards for your information.

We do not use the information you provide to make any automated decisions that might affect you.

We keep your information for the duration of the business relationship between you and JAO and for a period of minimum five (5) years following the termination of the business relationship.

2.5 Customer feedback and satisfaction

We are committed to continually improving our services and may, therefore, collect feedback from you through methods such as surveys and questionnaires. 

This feedback helps us improve the quality of our services and better meet your needs. 

Any personal data provided during this process will be handled in accordance with our privacy policy, used solely for service improvement purposes, and will not be shared with third parties without your consent.

Your information is stored within the European Union.

We keep your information for the duration of the business relationship between you and JAO and for a period of minimum five (5) years following the termination of the business relationship.

The results of the surveys and questionnaires are kept for a period of five (5) years.

This applies to all our clients and is part of our ongoing commitment to customer satisfaction.

2.6 Your rights as a data subject

By law, you can ask us what information we hold about you, and you can ask us to correct it if it is inaccurate. If we have asked for your consent to process your personal data, you may withdraw that consent at any time.

If we are processing your personal data for reasons of consent or to fulfil a contract, you can ask us to give you a copy of the information in a machine-readable format so that you can transfer it to another provider.

If we are processing your personal data for reasons of consent or legitimate interest, you can request that your data be erased.

You have the right to ask us to stop using your information for a period of time if you believe we are not doing so lawfully.

Finally, in some circumstances you can ask us not to reach decisions affecting you using automated processing or profiling.

To submit a request regarding your personal data by email, post or telephone, please use the contact information provided above in the Who Are We section of this policy.

2.7 Your right to complain

If you have a complaint about our use of information, we would prefer you to contact us directly in the first instance so that we can address your complaint. However, you can also contact the National Commission for Data Protection of Luxembourg ("CNPD") via their website at https://cnpd.public.lu/fr.html or write to them at:

National Commission for Data Protection, 15, Boulevard du Jazz, L-4370, Belvaux.

2.8 Updates to this privacy policy

We regularly review and, if appropriate, update this privacy policy from time to time, and as our services and use of personal data evolves. If we want to make use of your personal data in a way that we have not previously identified, we will contact you to provide information about this and, if necessary, to ask for your consent.

We will update the version number and date of this document each time it is changed.