Privacy Policy
1. Purpose of this Privacy Policy
The purpose of this privacy policy is to inform users of our website of the personal data we will collect, as well as the following information, where applicable:
a. The personal data we will collect
b. The use of the data collected
c. Who has access to the data collected
d. The rights of website users
e. The website’s cookie policy
This privacy policy operates alongside the general terms and conditions of use of our website.
2. Applicable Laws
In accordance with the General Data Protection Regulation (GDPR), this privacy policy complies with the following regulations:
Personal data must be:
a. processed lawfully, fairly, and in a transparent manner in relation to the data subject (lawfulness, fairness, transparency);
b. collected for specified, explicit, and legitimate purposes and not further processed in a manner incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes shall not be considered incompatible with the initial purposes in accordance with Article 89(1) (purpose limitation);
c. adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed (data minimization);
d. accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that inaccurate personal data, having regard to the purposes for which they are processed, are erased or rectified without delay (accuracy);
e. kept in a form that permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as they will be processed solely for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes in accordance with Article 89(1), subject to the implementation of appropriate technical and organizational measures required by the Regulation to safeguard the rights and freedoms of the data subject (storage limitation);
f. processed in a manner that ensures appropriate security of personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organizational measures (integrity and confidentiality).
Processing shall be lawful only if and to the extent that at least one of the following applies:
a. the data subject has given consent to the processing of their personal data for one or more specific purposes;
b. processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;
c. processing is necessary for compliance with a legal obligation to which the controller is subject;
d. processing is necessary in order to protect the vital interests of the data subject or of another natural person;
e. processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
f. processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, particularly where the data subject is a child.
For residents of Luxembourg, this privacy policy is intended to comply with the Government IT Centre (CTIE). In the event of inconsistencies between this document and Luxembourg legislation, Luxembourg law shall apply. If we identify inconsistencies, we will amend our policy to comply with the relevant law.
3. Consent
Users agree that by using our website, they consent to:
a. the conditions set out in this privacy policy;
b. the collection, use, and retention of the data listed in this policy.
4. Personal Data We Collect
Data Collected in a Non-Automatic Way
We may collect the following data when you perform certain functions on our website:
a. First and last name
b. Email address
c. Telephone number
d. Home address
e. Payment information
f. Autofill data
These data may be collected using the following methods:
Please note that we only collect data that helps us achieve the purpose stated in this privacy policy.
We will not collect additional data without informing you beforehand.
How We Use Personal Data
The personal data collected on our website will only be used for the purposes specified in this policy or indicated on the relevant pages of our website. We will not use your data beyond what we disclose.
The data we collect when the user performs certain functions may be used for the following purposes:
a. Preparation of quotations
b. Contacting users
c. Billing
d. File and case follow-up
4. Employees
We may disclose user data to any member of our organization who reasonably requires it to fulfill the purposes set out in this policy.
5. Third Parties
Third parties will not be able to access user data beyond what is reasonably necessary to achieve the given purpose.
6. Other Disclosures
We undertake not to sell or share your data with third parties, except in the following cases:
a. if required by law;
b. if required for any legal proceeding;
c. to prove or protect our legal rights;
d. to buyers or potential buyers of this company in the event that we seek to sell the company.
If you follow hyperlinks from our website to another website, please note that we are not responsible for and have no control over their privacy policies and practices.
7. How Long We Store Personal Data
User data will be retained for a period of five years.
We will ensure that users are notified if their data is retained for longer than this period.
8. How We Protect Your Personal Data
To ensure your security, we use the Transport Layer Security (TLS) protocol to transmit personal information within our system.
All data stored in our system is securely protected and accessible only to our employees. Our employees are bound by strict confidentiality agreements, and a breach of such agreements may result in dismissal.
While we take all reasonable precautions to ensure that user data is secure and users are protected, there always remains a risk of harm. The Internet as a whole may sometimes be insecure, and therefore we are unable to guarantee the security of user data beyond what is reasonably practical.
9. Minors
The GDPR specifies that persons under the age of 15 are considered minors for the purposes of data collection. Minors must have the consent of a legal representative for their data to be collected, processed, and used.
10. Your Rights as a User
Under the GDPR, users have the following rights as data subjects:
a. right of access
b. right to rectification
c. right to erasure
d. right to restrict processing
e. right to data portability
f. right to object
Further information regarding these rights can be found in Chapter 3 (Articles 12–23) of the GDPR.
11. How to Modify, Delete, or Challenge the Data Collected
If you would like your information to be deleted or modified in any way, please contact our privacy officer here:
Hilal SENGUL
10 rue Sangels I L-5425 Gostingen
hilal@luxdebarras.lu
12. Cookie Policy
A cookie is a small file stored on a user’s hard drive by a website. Its purpose is to collect data relating to the user’s browsing habits.
We use the following types of cookies on our website:
a. Functional cookies: We use these to remember all selections you make on our website so that they are saved for future visits.
b. Analytical cookies: These allow us to improve the design and functionality of our website by collecting data on the content you access and interact with while using our website.
c. Targeting cookies: These cookies collect data on how you use the website and your preferences. This enables us to make the information you see on our website more promotional and targeted to you.
You may choose to be notified each time a cookie is transmitted. You may also choose to disable cookies entirely in your Internet browser; however, this may reduce the quality of your user experience.
13. Amendments
This privacy policy may be amended from time to time in order to maintain compliance with the law and to reflect any changes to our data collection process. We recommend that our users review our policy periodically to ensure they remain informed of any updates. Where appropriate, we may notify users by email of changes made to this policy.
14. Contact
If you have any questions for us, please do not hesitate to contact us using the following details:
Telephone: 621 80 40 11
Email: info@luxdebarras.lu
Registered office: 34 Rue Philippe II L-2340 Luxembourg
Effective date: 27/07/2015