Data protection is for us an absolute priority. The use of our website is possible without indication of personal data; however, if a data subject wishes to use special services of the company via our website, the processing of personal data may be necessary. If the processing of personal data is necessary and there is no legal basis for such processing, we usually obtain the consent of the person concerned.
The processing of personal data, such as the name, address, e-mail address or telephone number of a data subject, must always comply with the General Data Protection Regulation (GDPR) and the national data protection rules. protection of the data that is applicable to us. Through this data protection policy, we wish to inform the general public of the nature, scope and purpose of the personal data we collect, use and process. In addition, the persons concerned are informed, by means of this data protection declaration, of the rights to which they are entitled.
As controller, we have implemented many technical and organizational measures to ensure the most comprehensive protection of personal data processed through this website. However, data transmissions via the Internet may in principle have security deficiencies, so that absolute protection can not be guaranteed.
Name and address of the controller
Data controller for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in the Member States of the European Union and other provisions on data protection:
9B Low Street L-4963 Clémency, Luxembourg
+352 691 20 55 66
This data protection declaration is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our privacy statement must be legible and understandable to the general public, as well as to our customers and business partners. To do this, we would first like to explain the terminology used.
In this privacy statement, we use the following terms:
a.) Personal data
Personal data means any information relating to an identified or identifiable natural person ("data subject"). An identifiable natural person is a person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or one or more specific factors the physical, physiological, genetic, mental, economic, economic, cultural or social identity of that natural person.
b.) Purpose of the data
The data subject is any identified or identifiable natural person whose personal data are processed by the controller.
Processing is any transaction or set of operations carried out on personal data or sets of personal data, whether or not by automated means, such as collection, registration, organization, structuring, storage, adaptation or modification, retrieval, consultation, use, disclosure by transmission, dissemination or any other form of provision, alignment or combination, restriction, erasure or destruction.
d.) Restriction of treatment
Limiting processing is the marking of stored personal data in order to limit their processing in the future.
Profiling is any form of automated processing of personal data consisting in the use of personal data to evaluate certain aspects of the personality of a natural person, in particular to analyze or predict aspects concerning the performance of that natural person. at work, economic situation, health, personal preferences, interests, reliability, behavior, place or movements.
Pseudonymisation is the processing of personal data in such a way that personal data can no longer be attributed to a given person without the use of additional information, provided that such additional information is kept separately and made the subject of technical and organizational measures to ensure that personal data are not attributed to an identified or identifiable natural person.
g.) Controller or controller responsible for processing
The controller is the natural or legal person, the public authority, the agency or any other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by the law of the Union or of the Member State, the controller or the specific criteria for his appointment may be laid down by Union or Community law. Member state.
The controller is a natural or legal person, a public authority, an agency or any other body that processes personal data on behalf of the controller.
The recipient is a natural or legal person, a public authority, an agency or other body to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the context of a particular investigation in accordance with Union or Member State legislation shall not be considered as recipients; the processing of these data by these public authorities must comply with the data protection rules applicable according to the purposes of the processing.
j.) Third party
A third party is a natural or legal person, a public authority, an agency or an organization other than the data subject, the controller, the processor and the persons authorized to process personal data directly under the authority of the responsible for the treatment.
The consent of the data subject is a freely given, specific, informed and unequivocal indication of the wishes of the data subject by which, by a declaration or by a clear affirmative action, he / she agrees to the processing of personal data concerning him / her. .
The data subject may, at any time, prevent the setting up of cookies on our website by means of a corresponding setting of the Internet browser used, and may therefore permanently refuse the setting up of cookies. In addition, cookies already configured can be deleted at any time via an Internet browser or other software. This is possible in all popular Internet browsers. If the person concerned disables the setting of cookies in the Internet browser used, all the features of our site are not fully usable.
Collection of general data and information
Our website collects a series of data and general information when a concerned person or an automated system calls the website. This data and general information is stored in the server log files.
Can be collected:
(1) types and versions of browsers used,
(2) the operating system used by the access system,
(3) the website from which an accessing system reaches our website (referrals),
(4) the sub -websites,
(5) the date and time of access to the website,
(6) an internet protocol address (IP address),
(7) the ISP of the access system, and
(8) any other similar data and the information that can be used in case of attacks against our computer systems.
When we use this data and general information, we do not draw any conclusions about the person concerned.
This information is necessary for (1) to properly provide the content of our website, (2) optimize the content of our website as well as its advertising, (3) ensure the long-term viability of our computer systems and our technology and (4) provide law enforcement authorities with information necessary for criminal prosecution in the event of a cyber attack. As a result, we statistically analyze anonymously collected data and information in order to increase the data protection and data security of our company, and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from any personal data provided by a data subject.
Rights of the person concerned
a.) Confirmation right
Each data subject has the right granted by the European legislator to obtain from the data controller the confirmation of the processing or not of the personal data concerning him / her. If a data subject wishes to avail himself of this right of confirmation, he may at any time contact an employee of the controller.
b.) Right of access
Each person concerned has the right granted by the European legislator to obtain from the person responsible free information on his / her personal data kept at all times and a copy of this information. In addition, the European directives and regulations grant the data subject the following information:
the goals of the treatment;
the categories of personal data concerned;
the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations;
where possible, the period for storing personal data or, if this is not possible, the criteria used to determine that period;
the existence of the right to ask the controller to rectify or delete personal data, or the restriction of the processing of personal data concerning the data subject, or to oppose such processing;
the existence of the right to lodge a complaint with a supervisory authority; when the personal data are not collected from the data subject, all available information as to their source; the existence of automated decision-making, including profiling, referred to in Article 22, paragraphs 1 and 4, of the RGPD and, at least in these cases, significant information on the logic involved, as well as on the importance and the consequences envisaged In addition, the data subject has the right to obtain information on the transfer of personal data to a third country or to an international organization. If this is the case, the data subject has the right to be informed of the appropriate guarantees relating to the transfer. If a data subject wishes to avail himself of this right of access, he may, at any time, contact employee of the controller.
c.) Right of rectification.
Each person concerned has the right granted by the European legislator to obtain from the data controller, without undue delay, the rectification of the inaccurate personal data concerning him / her. In view of the purposes of the processing, the data subject has the right to supplement incomplete personal data, including by providing a complementary statement. If a data subject wishes to exercise this right of rectification, he may, at the at any time, contact an employee of the controller.) Right of cancellation (Right to be forgotten) Each data subject has the right granted by the European legislator to obtain from the data controller the deletion of personal data concerning him / her without indu deadline, and the data controller has the obligation to erase the personal data without undue delay when one of the following reasons applies, as long as the treatment is not necessary: Personal data are no longer necessary for the purposes for which they were collected or otherwise treated.
The data subject withdraws the consent on which the processing is based in accordance with Article 6, paragraph 1, point (a), CPR or Article 9, paragraph 2, point (a), of the DPSP and where no other legal reason for the treatment. The data subject objects to the processing in accordance with 21 1, paragraph 21, and there is no compelling legitimate reason justifying the processing, or the data subject objects to the processing in accordance with Article 2, paragraph XNUMX, from the RGPD. Personal data has been illegally processed. Personal data must be erased for the fulfillment of a legal obligation in the law of the Union or of the Member State to which the controller is subject. Personal data has been collected in connection with the information society services offered under 8, paragraph 1, of the GDPR. If one of the above reasons applies, the data subject wishes to request the deletion of the personal data we keep he may at any time contact an employee of the controller. The employee must promptly ensure that the erasure request is immediately satisfied. Where the controller has made public personal data and is obliged, under Article 17, paragraph 1, to delete personal data, the data controller implementation, takes reasonable measures, including technical measures, to inform other controllers of the processing of personal data that the data subject has requested the deletion by those controllers of any link, copy or replication of such personal data, for as long as the treatment is not performed. Required fields. An employee will take the necessary action in individual cases.
e.) Right to restrict treatment.
Each data subject shall have the right granted by the European legislator to obtain from the data processing controller any of the following conditions: the data are disputed by the data subject during a period allowing the controller to verify the accuracy of the personal data. The processing is illegal and the person concerned opposes the erasure of personal data and instead asks for the restriction of their use. The controller no longer needs personal data for processing purposes, but it is required by the data subject for the establishment, exercise or defense of legal claims. The data subject objected to processing under 21, paragraph 1, of the DPRP pending verification if the legitimate reasons of the controller overrode those of the data subject. If one of the above conditions is fulfilled and a data subject wishes to request the restriction of the processing of personal data about us, it may at any time contact an employee of the controller. The employee will organize the restriction of the treatment.
f) Right to portability of data.
Each person concerned has the right granted by the European legislator, to receive the personal data concerning him / her, which have been provided to a controller, in a structured way, commonly used and machine readable format. He has the right to transmit this data to another unhindered controller of the controller to whom the personal data have been provided, provided that the processing is based on the consent referred to in Article 6, paragraph 1, point (a), of the RGPD or in point a ) 2) of the GDPR, or on a contract under 6, paragraph 1, point b), of the RGPD, and the processing is done by automated means, as long as the processing is not necessary for the execution of a task in the public interest or in the exercise of the public authority vested in the controller. In addition, by exercising its right to portability of data in accordance with Article 20, paragraph 1, of the RGPD, the data subject has the right to data transmitted directly from one controller to another, when technically feasible and does not adversely affect the rights and freedoms of others.To assert the right to portability of data, the data subject may at any time contact an employee.
g. ) Right of opposition
Each person concerned has the right granted by the European legislator to oppose, at any time, for reasons relating to his particular situation, the processing of personal data concerning him, which is based on points e) or f) Article 6, paragraph 1, of the RGPD. This also applies to profiling based on these provisions. We no longer process personal data in case of objection, unless we can show legitimate and compelling reasons for the treatment that goes beyond the interests, rights and freedoms of the data subject. the establishment, exercise or defense of legal claims.If we process personal data for direct marketing purposes, the data subject has the right to object at any time to the processing of personal data concerning him for such marketing. This applies to profiling insofar as it is related to such direct marketing. If the data subject objects to processing for direct marketing purposes, we will no longer process personal data for these purposes. In addition, the data subject has the right, for reasons related to his particular situation, to oppose personal data relating to him for purposes of scientific or historical research, or for statistical purposes in accordance with 89 1, paragraph XNUMX, unless the processing is necessary for the performance of a task performed for reasons of public interest. exercise the right of opposition, the person concerned can contact any employee. In addition, the data subject is free in the context of the use of information society services, and notwithstanding Directive 2002 / 58 / EC, to use his right of opposition by automated means by using technical specifications.
h.) Automated individual decision making, including profiling
Each person concerned has the right granted by the European legislator not to be the subject of a decision based solely on automated processing, including profiling, producing legal effects concerning him or affecting significantly the decision (1) is not necessary to conclude or execute a contract between the data subject and a controller, or (2) is not authorized by the law of the Union or the Member States to which the controller treatment is submitted and which also provides for appropriate measures to protect the rights and freedoms of the data subject and the legitimate interests, or (3) does not rely on the explicit consent of the data subject.If the decision (1) is necessary f or (2) it is based on the explicit consent of the person concerned, we will implement appropriate measures to protect the rights and freedoms and the legitimate interests of the person concerned. , at least the right to obtain a human intervention from the controller, to express his / her point of view and to challenge the decision. If the data subject wishes to exercise the rights relating to the automated individual decision making, can: at any time, contact an employee.
i.) Right to withdraw data protection consent
Each person concerned has the right granted by the European legislator to withdraw their consent to the processing of their personal data at any time.If the person concerned wishes to exercise the right to withdraw consent, he or she may, at any time, contact an employee. Legal basis for treatment Art. 6 (1) on a GDPR serves as the legal basis for processing operations for which we obtain consent for specific processing purposes. If the processing of personal data is necessary for the performance of a contract to which the data subject is a party, as is the case, for example, where processing operations are necessary for the supply of goods or any other service, the treatment is on the basis of 6, paragraph 1, b GDPR. The same applies to the processing operations necessary for the performance of pre-contractual measures, for example in the case of investigations concerning your products or services. Our company is subject to a legal obligation whereby the processing of personal data is necessary, as for the fulfillment of tax obligations, the treatment is based on art. 6 (1) on c GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if a visitor was injured in our business and his or her name, age, health insurance data or other vital information would be passed on to a doctor, a hospital or a third party. Then the treatment would be based on Art. 6 (1) on d GDPR. Finally, the processing operations could be based on the 6 article, paragraph 1, lit. f GDPR. This legal basis is used for processing that is not covered by any of the above-mentioned legal grounds, if the processing is necessary for the legitimate interests of our company or a third party, unless such interests are overridden by the interests or the fundamental rights and freedoms of the data subject that require the protection of personal data. Such treatments are particularly allowed because they have been specifically mentioned by the European legislator. It considered that a legitimate interest could be presumed if the data subject was a customer of the controller (recital 47, second sentence, GDPR). Erasure and blocking of personal dataThe data controller processes and stores the personal data of the data subject only. period necessary to achieve the objective of storage, or to the extent that it is granted by the European legislator or other legislators in the laws to which the controller is subject. If the purpose of storage is not applicable or if a retention period prescribed by the the European legislator or other competent legislator expires, personal data is systematically blocked or erased in accordance with legal requirements. Legitimate interests pursued by the controller or by a third party where the processing of personal data is based on Article 6, paragraph 1. f GDPR our legitimate interest is to conduct our business for the welfare of all our employees and shareholders.Period for which personal data will be stored.
The criteria used to determine the period of storage of personal data is the respective legal status the duration of the conversation. After the expiry of this period, the corresponding data is deleted regularly, as long as it is no longer necessary for the performance of the contract or the conclusion of a contract. Provision of personal data as a legal or contractual requirement; Requirement to enter into a contract; Obligation of the data subject to provide the personal data possible consequences of failure to provide such data.
We specify that the provision of personal data is partly required by law (eg tax regulations) or may also result from contractual provisions (eg information on the contractual partner). Sometimes it may be necessary to conclude a contract that the data subject provides us with personal data, which must then be processed by us. The data subject is, for example, required to provide us with personal data when our company signs a contract with it. The non-communication of personal data would mean that the contract with the person concerned could not be concluded. Before the personal data are provided by the data subject, the data subject must contact any employee. The employee explains to the data subject whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, is an obligation to provide personal data and the consequences of non-provision of personal data. Payment method: data protection provisions on the use of PayPal as a payment processor On this site, the controller has integrated PayPal components. PayPal is an online payment service provider. Payments are processed through PayPal accounts, which represent virtual private or business accounts. PayPal is also able to process virtual credit card payments when a user does not have a PayPal account. A PayPal account is managed via an e-mail address, which is why there are no standard account numbers. PayPal allows you to trigger online payments to third parties or to receive payments. PayPal also accepts fiduciary functions and provides buyer protection services. PayPal's European operating company is PayPal (Europe) S.à.rl & Cie. SCA, 22-24 Boulevard Royal, 2449 Luxembourg, Luxembourg.If the data subject chooses "PayPal" as a payment option in the online shop during the ordering process, we automatically transmit the data of the data subject to PayPal. By selecting this payment option, the data subject accepts the transfer of personal data necessary for the processing of payments. Personal data sent to PayPal is usually the first name, last name, address, e-mail address, IP address, phone number shadow, mobile phone number, or other data needed for payment processing. The processing of the purchase contract also requires these personal data, which are related to the respective order. The purpose of data transmission is the processing of payments and the prevention of fraud. The controller will transfer the personal data to PayPal, in particular, if a legitimate interest in the transmission is given. Personal data exchanged between PayPal and the data controller will be sent by PayPal to the credit bureaus. This transmission is intended for identity and credit checks. PayPal will, where appropriate, transmit personal data to affiliates and service providers or subcontractors to the extent necessary to fulfill contractual obligations or to process data. in the order. subject has the option to revoke consent for the processing of personal data at any time from PayPal. A revocation will have no effect on personal data that must be processed, used or transmitted in accordance with the payment processing (contractual). The applicable data protection provisions of PayPal can be retrieved under https://www.paypal.com/us/ webapps / mpp / ua / privacy-full.Registration on our websiteThe data subject has the possibility to register on the website of the controller with the indication of the personal data. The personal data transmitted to the controller is determined by the respective input mask used for the recording. The personal data entered by the data subject is collected and stored exclusively for internal use by the controller and for his own purposes. The controller may request the transfer to one or more processors (eg a parcel service) which also uses personal data for internal purposes attributable to the controller. By registering on the controller's website the IP address assigned by the Internet service provider (ISP) and used by the data subject, date and time of registration are also stored. The storage of this data takes place in the context that it is the only way to prevent misuse of our services, and, if necessary, to investigate the offenses committed. Because storing this data is necessary to secure the controller. These data are not passed on to third parties unless there is a legal obligation to transmit the data, or if the transfer serves the purpose of criminal prosecution. The registration of the data subject, with the voluntary indication of the personal data, is intended to allow the controller to offer the content or services of the data subject that can only be offered to registered users because of the nature of the problem in question. Registered persons are free to modify the personal data specified at registration at any time or to delete them completely from the data controller's data storage. The controller shall provide, at any time, information on request to each person concerned. what personal data is stored on the data subject. In addition, the controller corrects or erases the personal data at the request or indication of the data subject, as long as there is no legal obligation for storage. All employees of the controller are in this regard available to the person concerned as a contact person.Registration to the Newsletter On our website, users have the opportunity to subscribe to the newsletter of our company . The input mask used for this purpose determines what personal data is transmitted, as well as when the newsletter is ordered from the controller. We inform our customers and business partners regularly through a newsletter on corporate offers. The company newsletter can only be received by the data subject if (1) the data subject has a valid email address and (2) the data subject's registers for sending the newsletter. A confirmation e-mail will be sent to the e-mail address registered by a data subject for the first time for sending a newsletter, for legal reasons, as part of the double opt procedure. -in. This confirmation email is used to prove whether the owner of the email address as a data subject is authorized to receive the newsletter. During the subscription to the newsletter, we also store the IP address of the computer system assigned by the Internet Service Provider ) and used by the person concerned at the time of registration, as well as the date and time of registration. The collection of this data is necessary to understand the misuse (if any) of the e-mail address of a data subject at a later date, and thus serves the purpose of the legal protection of the controller. Personal data collected as part of a subscription to the newsletter will only be used to send our newsletter. In addition, newsletter subscribers may be informed by e-mail as long as it is necessary for the operation of the newsletter service or a registration in question, as may be the case in The event of changes to the newsletter offer, or in case of change of technical circumstances. There will be no transfer of personal data collected by the newsletter service to third parties. Subscription to our newsletter may be terminated by the person concerned at any time. The consent to the storage of personal data, which the data subject has given for the sending of the newsletter, may be revoked at any time. For the purpose of revoking consent, a corresponding link is found in each newsletter. It is also possible to unsubscribe from the newsletter at any time directly on the controller's website, or to communicate this differently to the controller. Follow-up of newsletters. Our newsletters contain tracking pixels. A tracking pixel is a miniature graphic embedded in these emails, which are sent in HTML format to allow the logging and analysis of log files. This allows a statistical analysis of the success or failure of online marketing campaigns. Based on the built-in tracking pixel, we can see if and when an email was opened by a concerned person, and what links in the email were called by the people concerned. This personal data collected in the pixels of contained in the ballots are stored and analyzed by the controller to optimize the sending of the newsletter, as well as to better adapt the content of future newsletters to the interests of the person concerned. This personal data will not be passed on to third parties. The persons concerned have the right at any time to revoke their declaration of consent to receive newsletters. After a revocation, this personal data will be erased by the controller. We automatically consider withdrawing the receipt of the newsletter as a revocation. Possibility of contact via the website. Our website contains information that allows a quick electronic contact to our company, as well as direct communication with us via an e-mail address. If a data subject contacts the controller by e-mail or via a contact form, personal data transmitted by the data subject is automatically stored. Such personal data transmitted on a voluntary basis by a data subject to the data controller is stored for the purpose of processing or contacting the data subject. There is no transfer of this personal data to third parties