# Privacy Policy

Protecting your personal data matters to us. Here you can find out which data we process when you visit progreen.lu, for what purpose and on what legal basis.

## 1. Controller

The controller responsible for data processing on this website within the meaning of the General Data Protection Regulation (GDPR) is:

- Company: **Progreen S.à r.l.**
- Address: 8 Z.I Um Woeller, L-4410 Soleuvre, Luxembourg
- Phone: [+352 691 834 633](tel:+352691834633)
- Email: [info@progreen.lu](mailto:info@progreen.lu)

Our company is not legally required to appoint a data protection officer. If you have any questions about data protection, please contact us directly using the details above.

## 2. Legal bases

We process personal data solely in accordance with the GDPR and the Luxembourg Law of 1 August 2018 on the organisation of the National Data Protection Commission and the general data protection framework. Depending on the purpose, we rely on:

- Art. 6(1)(a) GDPR – your consent, such as for Google Ads
- Art. 6(1)(b) GDPR – performance of a contract or pre-contractual steps, such as an enquiry about consultation, installation or maintenance
- Art. 6(1)(c) GDPR – a legal obligation, such as tax and commercial record-keeping requirements or proof of consent
- Art. 6(1)(f) GDPR – our legitimate interest, such as in a secure and functioning website

The sections below state which legal basis applies to each processing activity.

## 3. Hosting and server log files

This website is hosted by Vercel Inc., 440 N Barranca Avenue #4133, Covina, CA 91723, USA. Each time a page is accessed, Vercel automatically processes data transmitted by your browser and stores it in server log files:

- IP address
- date and time of access
- page or file requested
- referrer URL (the page visited previously)
- browser type and version, operating system

We need this data to deliver the website, to ensure its stability and security, and to fend off attacks. The legal basis is our legitimate interest in a secure and functioning website (Art. 6(1)(f) GDPR). We do not combine this data with other data sources. Log files are stored only briefly and then deleted automatically.

Vercel acts as our processor (Art. 28 GDPR) and operates a global server network, so processing in the USA is possible. Vercel is certified under the EU-U.S. Data Privacy Framework, for which the European Commission has adopted an adequacy decision (Art. 45 GDPR). More information: [vercel.com/legal/privacy-notice](https://vercel.com/legal/privacy-notice).

## 4. Content delivery (Sanity)

We manage the content of this website with the Sanity content management system, provided by Sanity AS (Norway) and Sanity US Inc. (USA). So that content and images are always up to date, your browser may connect to Sanity's servers when you view our pages. In particular, your IP address, the date and time and information about your browser are transmitted.

The legal basis is our legitimate interest in presenting our content reliably and up to date (Art. 6(1)(f) GDPR). Sanity processes this data as a processor; for transfers to the USA, Sanity relies on the European Commission's standard contractual clauses (Art. 46(2)(c) GDPR). More information: [sanity.io/legal/privacy](https://www.sanity.io/legal/privacy).

## 5. Videos (DigitalOcean Spaces)

The videos on our website are stored in the Spaces storage service of DigitalOcean, LLC, 105 Edgeview Drive, Ste. 425, Broomfield, CO 80021, USA, in its Frankfurt am Main data centre. They are delivered via a content delivery network: when your browser loads a page with a video, it fetches the video file directly from DigitalOcean's servers. Your IP address, the date and time and information about your browser are transmitted in the process.

The legal basis is our legitimate interest in delivering our media quickly and reliably (Art. 6(1)(f) GDPR). DigitalOcean acts as a processor and is certified under the EU-U.S. Data Privacy Framework (Art. 45 GDPR). More information: [digitalocean.com/legal/privacy-policy](https://www.digitalocean.com/legal/privacy-policy).

## 6. Web analytics with Matomo

To understand how our website is used and to improve it, we use the open-source software Matomo. Matomo is operated by a service provider, which processes the data on our behalf as a processor, and hosted by Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany.

In particular, the following is recorded:

- IP address – shortened before it is analysed (IP anonymisation), so that it can no longer be clearly attributed to you
- the approximate region from which the page is accessed
- pages visited, date, time and length of visit
- referrer URL (the page visited previously)
- browser, operating system, screen resolution and language setting

We have configured Matomo so that it does not store any cookies in your browser (cookieless analytics).

The legal basis is our legitimate interest in analysing and improving our website (Art. 6(1)(f) GDPR). You can object to this tracking at any time. Your objection is stored in a cookie in your browser; if you delete your cookies, you will need to object again.

## 7. Cookie banner and consent (iubenda)

We obtain your consent to cookies and similar technologies through a cookie banner, which we run on iubenda's consent management platform. The provider is iubenda S.r.l., Via San Raffaele 1, 20121 Milan, Italy.

The banner is loaded from iubenda's servers with every page; in the process, your IP address and information about your browser and device are transmitted to iubenda. iubenda stores your choice in the cookies **\_iub\_cs-s4709147** and **\_iub\_previous\_preference\_id** (12 months each) so that the banner does not reappear on every page. As proof of your consent, the banner sends your choice, with a timestamp, to iubenda, where it is logged.

The legal basis is our legal obligation to obtain consent and to be able to demonstrate it (Art. 6(1)(c) in conjunction with Art. 7(1) GDPR). iubenda's cookies are strictly necessary for this purpose and do not require consent (Art. 4(3)(e) of the amended Luxembourg Law of 30 May 2005). iubenda processes the data as a processor on our behalf.

You can change your choice and withdraw any consent given with effect for the future at any time – using the button at the bottom right of every page or here:

## 8. Advertising with Google Ads

To measure how well our ads on Google perform, we use the Google tag from Google Ads. For users in the EU, the provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

The Google tag is loaded with every page. With your consent, it records whether you reached our website through one of our ads, which pages you visit here and whether you send us an enquiry through the contact form – without its content (conversion tracking). Google may also add visitors to our website to audiences to whom we show ads on other websites (remarketing). In particular, the following is transmitted:

- IP address
- pages visited, date and time
- referrer URL and, where applicable, the ID of the ad clicked
- information about your browser and device
- cookie identifiers, including those of any existing Google cookies

For this purpose, the Google tag sets cookies on our domain, in particular **\_gcl\_au** (90 days) and, if you arrive through an ad, **\_gcl\_aw** (90 days); Google may also set or read cookies on its own domains. If you are signed in to Google, Google may link the data to your account.

Without your consent, the Google tag neither sets nor reads cookies (Google Consent Mode). It then only sends Google cookieless signals – such as the fact that a page was viewed, your consent status and information about your browser and device; for technical reasons, your IP address is also transmitted.

The legal basis is your consent (Art. 6(1)(a) GDPR; Art. 4(3)(a) of the amended Luxembourg Law of 30 May 2005), which you can withdraw at any time with effect for the future (see [“Cookie banner and consent (iubenda)”](https://progreen.lu/en/privacy-policy#einwilligung)). Google processes the data as an independent controller; data may be transferred to Google LLC in the USA, which is certified under the EU-U.S. Data Privacy Framework (Art. 45 GDPR). More information: [policies.google.com/technologies/ads](https://policies.google.com/technologies/ads) and [policies.google.com/privacy](https://policies.google.com/privacy). You can turn off personalised ads at [myadcenter.google.com](https://myadcenter.google.com).

## 9. Contact form

When you send us an enquiry via the contact form, we process the information you enter:

- name
- email address
- phone number (optional)
- the content of your message

We use this data solely to handle your enquiry, answer follow-up questions, prepare a quotation or arrange an appointment. The legal basis is Art. 6(1)(b) GDPR where your enquiry is aimed at concluding a contract, and otherwise our legitimate interest in responding to enquiries (Art. 6(1)(f) GDPR).

To forward your enquiry to us by email, we use the Brevo service of Sendinblue SAS, 106 boulevard Haussmann, 75008 Paris, France, as a processor. Brevo is based in the European Union. More information: [brevo.com/legal/privacypolicy](https://www.brevo.com/legal/privacypolicy/).

We store your data until your enquiry has been fully dealt with. If it results in an order, we keep the correspondence for the statutory retention periods (up to ten years). Your name, email address and message are required for us to answer your enquiry; the phone number is optional.

## 10. Spam protection (Google reCAPTCHA)

To protect our contact form against automated spam, we use Google reCAPTCHA v3. For users in the EU, the provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

reCAPTCHA is only loaded once you use the form – if you merely read the page, no connection to Google is made. From then on, reCAPTCHA checks in the background whether the input comes from a human. To do so, your IP address, information about your browser and device, the page visited, your interaction with the form and any existing Google cookies in particular are transmitted to Google; reCAPTCHA may also set its own cookies.

The legal basis is our legitimate interest in protecting our form against abuse and spam (Art. 6(1)(f) GDPR). Data may be transferred to Google LLC in the USA; Google LLC is certified under the EU-U.S. Data Privacy Framework (Art. 45 GDPR). More information: [policies.google.com/privacy](https://policies.google.com/privacy).

## 11. Contact by email or phone

If you contact us by email or phone, we process the information you provide (such as your name, contact details and the subject of your enquiry) to deal with your request – on the same legal basis and with the same retention period as for the contact form.

## 12. Cookies

To measure our ads, we use Google Ads cookies (see [“Advertising with Google Ads”](https://progreen.lu/en/privacy-policy#google-ads)); when you use the contact form, Google reCAPTCHA may set cookies (see [“Spam protection (Google reCAPTCHA)”](https://progreen.lu/en/privacy-policy#recaptcha)). Web analytics with Matomo works without cookies; only if you object to it is your objection stored in a cookie (see [“Web analytics with Matomo”](https://progreen.lu/en/privacy-policy#matomo)).

iubenda stores your choice in the cookie banner in its own cookies (see [“Cookie banner and consent (iubenda)”](https://progreen.lu/en/privacy-policy#einwilligung)).

If you open a language version other than the one your browser prefers, we store your choice in the **NEXT\_LOCALE** cookie so that the website is shown to you in that language. It is a session cookie that is deleted when you close your browser. As it is strictly necessary for the display you requested, it does not require consent (Art. 4(3)(e) of the amended Luxembourg Law of 30 May 2005 on data protection in electronic communications); the legal basis for the processing is Art. 6(1)(f) GDPR.

You can set your browser to refuse cookies or to notify you before they are set. The website remains usable without cookies.

## 13. Fonts and icons

Fonts and icons are delivered together with the website by our hosting provider. No connection to Google Fonts or other third-party providers is made for this purpose.

## 14. External links

Our website links to third-party services, such as our shop on Letzshop, the Husqvarna dealer directory or Google Maps for directions. These are simple links: no data is transmitted to the provider concerned until you click a link. From then on, that provider's privacy policy applies.

## 15. Disclosure of data

We only disclose your personal data if:

- this is necessary to perform a contract or to take pre-contractual steps;
- we are legally obliged to do so; or
- you have expressly consented.

Beyond that, only the service providers named in this policy receive data, to the extent described there. We do not sell data. For advertising purposes, only Google receives data, as described under [“Advertising with Google Ads”](https://progreen.lu/en/privacy-policy#google-ads).

## 16. Transfers to third countries

Vercel and DigitalOcean are based in the USA; Sanity and Google also process some data there. Data is only transferred to the USA on the basis of the European Commission's adequacy decision for the EU-U.S. Data Privacy Framework (Art. 45 GDPR), under which Vercel, DigitalOcean and Google LLC are certified, or of the European Commission's standard contractual clauses (Art. 46(2)(c) GDPR).

## 17. Retention period

Unless a more specific retention period is stated in this privacy policy, we store personal data only for as long as is necessary for the purpose concerned. If you make a justified request for erasure or withdraw your consent, we delete your data unless there are other legally permissible grounds for storing it – such as retention periods under tax or commercial law. In that case, we delete it once those grounds no longer apply.

## 18. Your rights

Under the GDPR, you have the following rights at any time:

- access, free of charge, to your stored data, its origin and recipients, and the purpose of the processing (Art. 15)
- rectification of inaccurate data (Art. 16)
- erasure of your data (Art. 17)
- restriction of processing (Art. 18)
- data portability (Art. 20)
- objection to processing (Art. 21)
- withdrawal of any consent given, with effect for the future (Art. 7(3)); this does not affect the lawfulness of processing carried out before the withdrawal

**Right to object (Art. 21 GDPR):** where we process your data on the basis of our legitimate interest (Art. 6(1)(f) GDPR), you have the right to object to this processing at any time on grounds relating to your particular situation; this also applies to profiling based on that provision. Once you object, we will no longer process the data concerned unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves the establishment, exercise or defence of legal claims (Art. 21(1) GDPR).

**Objection to direct marketing:** where your data is processed for direct marketing purposes, you may object to this processing at any time, including to profiling to the extent that it is related to such direct marketing. Once you object, your data will no longer be used for direct marketing purposes (Art. 21(2) GDPR).

To exercise your rights, simply send an informal message to the contact details given under [“Controller”](https://progreen.lu/en/privacy-policy#verantwortlicher).

## 19. Right to lodge a complaint

If you believe that the processing of your data infringes data protection law, you may lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, your place of work or the place of the alleged infringement. This right is without prejudice to any other administrative or judicial remedy. In Luxembourg, the competent authority is the:

**Commission nationale pour la protection des données (CNPD)**, 15, Boulevard du Jazz, L-4370 Belvaux, [cnpd.public.lu](https://cnpd.public.lu)

## 20. Data security

This website is transmitted exclusively in encrypted form via HTTPS (TLS). In addition, we take appropriate technical and organisational measures to protect your data against loss, misuse and unauthorised access. Please note that data transmission over the internet – for example by e-mail – may have security gaps; complete protection of data against access by third parties is not possible.

## 21. Changes to this policy

We update this privacy policy when our website or the services we use change, or when the law requires it. The version published here applies.

Last updated: October 2026

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## Contact

**Progreen S.à r.l.**  
8 Z.I Um Woeller  
L-4410 Soleuvre  
Luxembourg

- Phone: [+352 691 834 633](tel:+352691834633)
- Email: [info@progreen.lu](mailto:info@progreen.lu)
- Opening hours: Mon – Fri, 10:30 – 18:30

## Navigation

- [Robotic mowers](https://progreen.lu/en/robotic-mowers)
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- [Servicing](https://progreen.lu/en/servicing-repairs)
- [Garden service](https://progreen.lu/en/garden-service)
- [About us](https://progreen.lu/en/about-us)
- [Request advice](https://progreen.lu/en/contact)
- [Shop](https://letzshop.lu/en/vendors/progreen)
- [Husqvarna dealer page](https://progreen.husqvarnadealers.lu/)

## Legal

- [Legal notice](https://progreen.lu/en/legal-notice)
- [Privacy](https://progreen.lu/en/privacy-policy)
- [Terms](https://progreen.lu/en/terms-and-conditions)

Language: [Deutsch](https://progreen.lu/datenschutz) · [English](https://progreen.lu/en/privacy-policy) · [Français](https://progreen.lu/fr/politique-de-confidentialite)