Privacy Policy of Radio ARA

1. Introduction

Alter Echos s.à r.l.(RCS B40301), the publisher of Radio ARA, is committed to safeguarding your privacy. In this Privacy Policy, references to “we,” “us,” “our,” or “you” include Ara International Community Radio a.s.b.l. (RCS F12988), Mond Op a.s.b.l. (RCS F1221), and Graffiti a.s.b.l.(RCS F1224). This policy outlines how we process and use personal information while ensuring compliance with applicable data protection regulations and respecting your privacy.

Radio ARA, operated by Alter Echos s.à r.l., is responsible for processing personal data in accordance with the Luxembourg Data Protection Act 2018 and Regulation (EU) 2016/679 (General Data Protection Regulation – GDPR).

We are committed to:

1. Collecting and processing information fairly;
2. Retaining it only for specific, lawful purposes;
3. Processing it exclusively in ways consistent with its original purpose;
4. Keeping it secure and protected;
5. Ensuring its accuracy and updating it when necessary;
6. Guaranteeing that it is adequate, relevant, and not excessive;
7. Retaining it only as long as necessary for its intended purpose;
8. Providing individuals with access to their personal data upon request.

This policy applies exclusively to services managed by Radio ARA including Alter Echos s.à r.l., Ara International Community Radio a.s.b.l., Mond Op a.s.b.l., and Graffiti a.s.b.l..

 

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2. Collection and Use of Personal Data

We collect personal information when you:

– Inquire about our activities;

– Contact us via phone, text, or email;

– Register as a volunteer;

– Submit an on-air radio request;

– Subscribe to one of our services.

This information may include your name, title, email address, physical address, and telephone number.

Radio ARA does not intentionally collect personal data from website visitors. However, technical data such as IP addresses, browser details, and pages visited may be automatically collected for analytical and security purposes. If you contact us via email, we will store copies of your correspondence, along with our responses, on our servers.

To provide our services efficiently, we may share your information with third-party providers (e.g., Mailchimp for newsletter distribution, servers may be located outside the EU, and data is processed under their Privacy Policy). If we share your personal data as part of a service you have signed up for, we will inform you. Your data will not be shared with third parties or marketing companies without your explicit consent.

• Volunteer Registration → Consent. Personal data is processed based on your consent (GDPR Article 6). By registering, you agree to data collection for volunteer-related purposes.
• On-Air Requests → Legitimate Interest. Data (e.g., name, request content, optional contact info) is processed under legitimate interest (GDPR Article 6). You can use a pseudonym, request anonymity, or object to processing at any time.
• Newsletters → Consent. Your consent (GDPR Article 6) is required to receive newsletters. You can withdraw consent by unsubscribing, which will lead to your data being deleted unless legal retention applies.
• Technical Data (IP, Logs, etc.) → Legitimate Interest / Security Compliance. Technical data is processed under legitimate interest and, where necessary, for security compliance. It’s used for security, performance, and analytics, and is retained only as long as needed.

For all data processing cases, contact: gdpr{at}ara.lu for objections, questions, or exercising your rights.

 

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3. Storage and Availability of Recordings

Radio ARA records its live programming 24/7, with recordings stored for three months. Additionally, a local archival copy is retained indefinitely. Recordings made in the studio are also stored for 3 month before they get deleted. Access to these recordings is restricted to individuals with a volunteer agreement or an employment contract with one of Radio ARA’s affiliated organizations.

Podcasts are made available on our websites (ara.lu, radioara.org, graffiti.lu, aracityradio.com, sexpodcast.lu) for at least ten years unless individuals request the removal of specific content with legimit interest. Groups producing podcasts must inform Radio ARA if they wish to distribute them elsewhere, though they may still be available on our websites.

Furthermore Radio ARA is obligated by the Grand-Ducal Regulation of 6 November 2009 on Legal Deposit (Mémorial A225).

 

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4. Cookie management and Tracking Technologies

Radio ARA prioritizes user privacy and adheres to the General Data Protection Regulation (GDPR). This Cookies Policy outlines how cookies are used on Radio ARA’s website and how users can manage their cookie preferences.

Cookies are small files stored on a device to help improve website functionality, personalize the user experience, and analyze behavior. Radio ARA uses necessary cookies for website operation, functional cookies for remembering preferences, and performance cookies (e.g., Google Analytics) for data analysis. Non-essential cookies are only used after obtaining explicit consent.

Users can manage or opt out of cookies via browser settings, and they can disable Google Analytics tracking by using the Opt-Out Add-on. Disabling cookies may affect certain website features.

Cookies are stored for varying durations based on their purpose. Data from third-party cookies may be processed outside the EU, in accordance with the EU-US Data Privacy Framework.

Users have the right to withdraw consent or request the deletion of personal data at any time. This policy may be updated periodically, and the most recent version will always be available on the website. By continuing to use the site, users agree to this policy.

Radio ARA does not intentionally use cookies to track visitors. However, third-party services embedded on the website, such as social media platforms, streaming services, and analytics tools, may use cookies to enhance functionality and monitor usage. Visitors can control cookie preferences through browser settings.

Google Analytics 4 is used to measure website performance, analyze user behavior, and improve online services. The tool is configured with privacy in mind: IP addresses are not stored, data is largely anonymized, and processing begins only after users give explicit consent. Data is retained for 14 months and may be transferred to third countries under the EU-US Data Privacy Framework. Users can withdraw consent at any time and opt out of tracking through the Google Analytics Opt-Out Browser Add-on.

Payment processing is handled by Stripe. Stripe retains transaction and payment data only for the duration necessary to fulfill the transaction and comply with legal obligations. Sensitive data, such as full card numbers, is not stored beyond the time needed for processing, as it is tokenized and securely stored.

 

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5. Data Security and Retention

Radio ARA takes appropriate measures to ensure the security of any information shared with us. This includes password protection and routine server maintenance. We do not sell, lease, or share your email address with third parties without your explicit consent. However, we cannot be held responsible for unauthorized access or third-party actions.

Personal data is retained only as long as necessary to fulfill its intended purpose. Subscribers’ contact information is stored for as long as they remain subscribed. Volunteer data is kept as long as they are actively engaged with Radio ARA.

Stored personal data is encrypted where applicable, and access is limited to authorized personnel.

In case of a data breach involving personal information, Radio ARA will notify affected users and relevant authorities as required by GDPR.

 

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6. Legal Basis for Data Processing

All volunteers sign a consent form at the start of their involvement, agreeing to responsibility for equipment, listeners, and compliance with internal regulations. If Graffiti a.s.b.l. works with minors, parental authorization is required. Graffiti a.s.b.l. is also recognized as a youth service by the Ministry of Education.

In addition to consent, Radio ARA processes data based on other legal grounds, including legitimate interest and contractual necessity where applicable. Legitimate interest may apply in cases where data processing is required to ensure the proper functioning and security of our services, while contractual necessity applies when processing is essential to fulfill obligations under volunteer or service agreements.

Individuals have rights under GDPR, including:

– Access to their data;

– Rectification of inaccuracies;

– Deletion upon request;

– Restriction of processing in specific cases;

– Data portability where applicable;

– Objection to certain processing activities.

For content-related objections, the official regulatory body ALIA can be contacted. Alternatively, requests can be sent via email to gdpr{at}ara.lu. Consent withdrawals can also be processed by emailing gdpr{at}ara.lu. However request must show a legit interest and a detailed description of which content needs to be removed. Also must they be in line with contractual agreements.

 

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7. Third-Party Disclosures and Legal Obligations

Radio ARA does not share personal data with external entities, except in cases where:

– We are legally required to do so (e.g., via court orders, subpoenas, or statutes);

– It is necessary to enforce our terms and conditions;

– It is required to prevent fraud or protect legitimate interests.

Our websites (ara.lu, radioara.org, graffiti.lu, aracityradio.com, sexpodcast.lu) contain links to external websites. Radio ARA is not responsible for the privacy policies or practices of these third-party sites. Any breach of confidentiality by our staff is treated as serious misconduct and may result in disciplinary action.

If required by law (court order, subpoena), we may disclose personal data. If permitted, we will notify affected users before disclosure.

 

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8. Your Consent and Policy Updates

By using Radio ARA’s websites (ara.lu, radioara.org, graffiti.lu, aracityradio.com, sexpodcast.lu), you consent to the collection and use of your information as described in this policy. If we update this Privacy Policy, we will reflect the changes and notify users via email (if applicable).

If you wish to request access to your personal data or request corrections, updates, or deletions, please contact us via our official contact page or email gdpr{at}ara.lu, providing as much detail as possible to facilitate processing.

 

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9. Disclaimer

All information on the Radio ARA website is provided for informational and educational purposes only. While we strive to ensure accuracy, we do not make any warranties, express or implied, regarding the completeness, reliability, or suitability of the information provided. Radio ARA shall not be held liable for any damages resulting from the use or reliance on the website’s content. Users access the website at their own risk.

 

For further inquiries, please contact us at gdpr{at}ara.lu

Last Updated: 16.06.2025