Compliance with Data Protection Law
We acknowledge and undertake to comply with the laws and regulations governing the processing of personal data, including, but not limited to, the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (“GDPR”) and any other national applicable laws or regulations governing the processing of personal data in the framework of the Services.
Personal identification information
We may collect personal identification information from Users in a variety of ways, including, but not limited to, when Users visit our website, register on the website, fill out a form, sign a contract, purchase a product and in connection with other activities, use applications and benefit from Services proposed by us. Users may be asked for, as appropriate, name, date of birth, email address, mailing address, phone number, etc.
Non-personal identification information
We may collect non-personal identification information about Users whenever they use our website or application or other online service. Non-personal identification information may include technical information about Users’ means of connection, such as the operating system and the Internet service provider utilized, geographical information such as country of origin, behavioural information such as time spent on our website, as well as further non-personal analytical data to improve customer experience, products and services.
Each User recognizes and accepts that the performance of the Services may depend on the collection and processing of personal identification information and non-personal identification information.
Web browser cookies
We may use « cookies » to improve the User’s experience of the Services. In that case, the User’s Internet navigator places cookies on his hard drive to gather a certain set of information used to customize the navigation in the framework of the Services, thus enabling certain unique functionalities. For further information, please consult our Cookies Policy.
How we use collected information?
Principally, personal and non-personal identification information is used to provide the Users with the Services and to insure a full efficiency of the Services they have registered for or they requested in any other manner.
In this framework, we may collect and use Users’ personal and non-personal identification information for the following purposes:
• To improve Services: Information Users provided will help us to respond to certain Users’ requests.
• To personalize User experience: We may use non-personal identification information to understand how Users as a group use our Services.
• To improve our website presence as well as other communication tools or tools for specific Services: We may use feedback that Users provide to improve our products and services.
• To send periodic emails and other text messages and/or notifications: We may use the email address or mobile phone number provided by Users to respond to inquiries, questions, and/or other requests. If Users decide to opt-in to our notification list, they will receive periodic information that may include company news, updates, related product or service information, private sales, information from our service providers on joint projects etc. (the “Periodic Information Service”). In case Users would like to unsubscribe from the Periodic Information Service, we include detailed unsubscribe instructions at the bottom of each such email or other text message.
How do we protect personal identification information?
We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of Users’ personal identification information within the limits of our role with respect to the relevant Services (as certain specific services might be rendered by third parties).
Sharing personal information
However, Users non-personal identification information may be provided to third parties for marketing, advertising, or other uses.
(1) as long as we maintain an ongoing relationship with the User (e.g., where the User is a recipient of our services, or is lawfully included in our mailing list and has not unsubscribed);
(3) until the expiry of a period of two (2) months following the end of any applicable limitation period under applicable law; and
(4) with the User’ prior consent, until the expiry of any additional retention period.
We undertake to delete or to anonymise the User’ personal data upon expiry of the retention period as described above.
Data Security and data transfer
We have implemented appropriate technical and organizational security measures designed to protect the User personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of processing, in accordance with applicable law.
The User is responsible for ensuring that any personal data that he/she send to us are sent securely.
We do not transfer personal data to any third country nor to any international organisation, except as the case may be on the basis of:
• adequacy decisions;
• suitable Standard Contractual Clauses; or
• other valid transfer mechanisms under GDPR.
Data Accuracy and minimization
We take reasonable measures:
- to ensure that the User’ personal data are accurate and, where necessary, kept up to date and accurate; and
Data subject rights
Each User benefits under data protection law from a right of access, modification and opposition to the processing of his/her personal data, a right to delete and transfer his/her personal data by sending an email to firstname.lastname@example.org. Those rights may only be exercised within the limits of any contractual or legal obligation. Each User has also a right to lodge a complaint with the Luxembourg supervisory authority, namely the Commission Nationale pour la Protection des Données (National Data Protection Commission – Luxembourg (public.lu)
Acceptance of these terms