From 7c429057235c2209c8e4b379ac8505da231dedff Mon Sep 17 00:00:00 2001 From: t0kubetsu Date: Tue, 18 Aug 2026 21:08:49 +0200 Subject: [PATCH 1/8] fix: adopt the v3 legal texts for the account statements The PR #38 seed carried placeholder digests that correspond to no document, so a consent receipt could not be verified against a text (GDPR Art. 7(1) demonstrability, flagged in review). Until the DPO delivers the v4 texts, the live v3 documents are adopted provisionally: - terms_and_conditions -> version 2024-10 (last updated October 2024 per the page), https://testing.nc3.lu/terms-conditions/, digest of the canonical snapshot committed at docs/legal/terms-of-service-2024-10.md. Corrected in place: the placeholder version named no real text and no production registration exists. - privacy_policy -> NEW acceptance statement (the NFR requires explicit privacy consent at signup), version 2026-08-18 (page undated; snapshot date pins the text), https://testing.nc3.lu/privacy/, digest of docs/legal/privacy-statement-2026-08-18.md. Registration requires every active account-level acceptance, so it binds automatically. - scan_target_permission keeps its placeholder: per-launch attestation, and nothing in the v4.0 catalog is intrusive. The mock GET /statements mirrors the rows verbatim; the postgres suite registers against both acceptances. DPO v4 texts land as new version rows. --- docs/legal/privacy-statement-2026-08-18.md | 123 +++++++++++++ docs/legal/terms-of-service-2024-10.md | 170 ++++++++++++++++++ ..._legal_texts_for_the_account_statements.py | 98 ++++++++++ .../domains/statements/router.py | 22 ++- tests/test_auth_postgres.py | 5 +- 5 files changed, 412 insertions(+), 6 deletions(-) create mode 100644 docs/legal/privacy-statement-2026-08-18.md create mode 100644 docs/legal/terms-of-service-2024-10.md create mode 100644 migrations/versions/2026_08_18_d7e3f1a2b4c6_adopt_v3_legal_texts_for_the_account_statements.py diff --git a/docs/legal/privacy-statement-2026-08-18.md b/docs/legal/privacy-statement-2026-08-18.md new file mode 100644 index 0000000..d9520e3 --- /dev/null +++ b/docs/legal/privacy-statement-2026-08-18.md @@ -0,0 +1,123 @@ + + +# PRIVACY STATEMENT + +The Luxembourg House of Cybersecurity (hereinafter referred to as LHC) +collects and processes personal data in accordance with the applicable data protection legislations such as, but +not +limited to, Regulation (EU) 2016/679 on the protection of natural persons with regards to the processing of +their +personal data and the free movement of such data (“GDPR”) and the national law adopting GDPR. + +It may occur that we change or amend our Privacy Policy in order to ensure that its content accurately reflects +regulatory developments. Any such modification, if substantial, will be clearly communicated to you, either via +the +website or via other appropriate means. The latest applicable version will be available on our website. + +Should you have any questions or remarks regarding this Privacy Policy, do not hesitate to contact us at +privacy@lhc.lu + +## PROCESSING OF PERSONAL DATA + +By “personal data” we understand any information that can identify you, both directly and indirectly. + +By “processing” we refer to anything we do with such personal data, including collection, recording, +organization, +structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, +dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction. + +By “data controller” we understand the person responsible for the processing of your personal data, this is the +entity which determines the means and purpose of the processing activities. + +For our Testing Platform website and all related services, the data controller is: + +Luxembourg House of Cybersecurity g.i.e., 122 rue Adolphe Fischer, L-1521 Luxembourg + +Tel: (+352) 274 00 98 601 + +Email: privacy@lhc.lu + +## WHAT PERSONAL DATA DO WE COLLECT ON OUR WEBSITE AND TO WHICH END? + +When you are surfing our Testing Platform website, we collect and process web server logs, including IP +addresses, +user-agents, URLs, date and time logs. We collect those logs for our legitimate interest as these logs enable +the +technical and functional management of our website. + +When you register to the Testing Platform, we process and collect certain personal data. The types of personal +information that are collected from you include: name and family name of the contact person, username and +password, +email address as well as the company name and full. + +When you contact us by mail, we process your contact information and any other details you provide us. We will +use +these details, if provided, for further case management around the issue resolution. + +Your personal data is collected for registration, billing and troubleshooting purposes. + +We confirm that we process your personal data in a fair and lawful manner and only for the explicit and +legitimate +purposes as above-mentioned. At all times, we strive to ensure that your personal data is adequate, relevant and +not +excessive in relation to the purposes for which they are processed. + +In case you enter and use one of the websites that may be linked to this website, personal data will processed +according to the privacy policies of these respective infrastructures. + +## HOW LONG DO WE RETAIN YOUR PERSONAL DATA? + +In no circumstances, we keep your personal data for a longer period than strictly necessary to fulfil the purpose +for which it was collected. If you decide to delete your account, or LHC decides to delete your +account after one year of inactivity on the Testing Platform, we inform you that your related personal data will +be +replaced in our Database with a string called "DELETED”. The data collected about servers that have been added +by +you as user will not be deleted as we might use them internally, however they will not be connected to you +anymore, +since your account gets anonymized. + +However, if requested by local and national law, certain personal data may be retained for a longer period. For +instance, for accounting purposes, such as, but limited to, payment of the services fees, data will be retained +for +the time required by the national law and for no longer than ten years). + +## SHARING PERSONAL DATA + +We formally confirm that we will not sell, rent or otherwise commercially transfer to or share with a third party +any personal data. + +The data submitted will only be made available to LHC personnel for the above mentioned +purposes. + +As our web server is hosted and managed in Luxembourg, your personal data is in no circumstances transferred to +third countries outside the EU. + +## SECURITY OF YOUR PERSONAL DATA + +We are striving to keep your personal data secure. To that end, we have adopted the appropriate legal, +organizational and technical precautions to prevent any unauthorized access and use of your personal data. These +measures include but are not limited to the encryption of all traffic between our website and your browser. +YOUR RIGHTS AS A DATA SUBJECT + +At LHC we aim to be transparent, not only about how we process personal data about you, but also +about +your rights that are linked to such processing. + +In particular, you have the right to access your personal data, to obtain the updating, the adjustment and the +erasure of the personal data and you can exercise the rights to restrict and to object the processing. You can +exercise the rights provided by articles 15 and the following of the GDPR contacting the following email address +privacy@lhc.lu . +In order to avoid unlawful access to your personal data, we will request you to provide a proof of your +identity. If +you have any queries about this Privacy Notice or experiencing any other privacy issue, we are striving to +promptly +dealing with any privacy-related complaints. +If you have a complaint related to the processing of your personal data by LHC, please contact +us. diff --git a/docs/legal/terms-of-service-2024-10.md b/docs/legal/terms-of-service-2024-10.md new file mode 100644 index 0000000..35c34be --- /dev/null +++ b/docs/legal/terms-of-service-2024-10.md @@ -0,0 +1,170 @@ + + +# Terms of Service + +These terms govern use of the website https://testing.nc3.lu . To use the +website, you must agree to these terms with +Luxembourg House of Cybersecurity (hereinafter referred to as LHC) the company that runs the website. +LHC may offer other products and services, under different terms. These terms apply only to use of +the +website. + +Skip to: + +- Your Permission to Use the Website + +- Conditions for Use of the Website + +- Acceptable Use + +- Content Standards + +- Your Account + +- Your Content + +- Termination + +- Disputes + +- Contact + +- Changes + +## Your Permission to Use the Website + +Subject to these terms, LHC gives you permission to use the website. You can't transfer it to +anyone +else. Others need to agree to these terms for themselves to use the website. + +## Conditions for Use of the Website +Your permission to use the website is subject to the following conditions: + +- You must be at least thirteen years old. + +- You may no longer use the website if LHC contacts you directly to say that you may not. + +- You must use the website in accordance with Acceptable Use and Content Standards. + +## Acceptable Use + +- You may not break the law using the website. + +- You may not use or try to use another's account on the website without their specific permission. + +- You may not buy, sell, or otherwise trade in user names or other unique identifiers on the website. + +- You may not send advertisements, chain letters, or other solicitations through the website, or use the +website to +gather addresses for commercial mailing lists. + +- You may not automate access to the website, or monitor the website, such as with a web crawler, browser +plug-in +or add-on, or other computer program that is not a web browser. You may crawl the website to index it for a +publicly +available search engine. + +- You may not use the website to send e-mail to distribution lists, newsgroups, or group mail aliases. + +- You may not falsely imply that you're affiliated with or endorsed by LHC. + +- You may not hyperlink to images or other non-hypertext content on the website. + +- You may not remove any marks showing proprietary ownership from materials you download from the website. + +- You may not show any part of the website on other websites with +