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Privacy Policy for Website and for LuxTrust Mobile Application

Last update – 08/04/2021

LuxTrust uses its best endeavours to respect your privacy while you visit this website and while you download and use the LuxTrust Mobile Application and understands just how important this is to you. To this end, we do our utmost to respect your privacy in connection with your use of this website or the use of the LuxTrust Mobile Application. The terms “LuxTrust” or “we” or “our” or “us” refer to Luxtrust S.A. (LuxTrust), the entity acting as data controller (that is, the company which determines why and how to process personal data) in relation to the processing of your information on this website and on the LuxTrust Mobile Application. We shall take all necessary measures to ensure that the personal data we hold about you is processed correctly and lawfully. We shall also take all necessary steps to implement and comply with this Privacy Policy.

Collection and use of personal data

For website:
We collect your personal data at various points, including:

  • when you navigate through our website; and
  • when you interact with us through our website, for example via electronic forms that you have to fill in when you order a product or a service offered via the website, when you request information [or when using our website research tool]. In this context, the following categories of personal data may be given or collected via the website: your name, date of birth, phone number, email address, home address, country, types of services received or products bought, financial and banking information and any other personal data reasonably related to the conduct of LuxTrust’s business or to the operation of its website.

For LuxTrust Mobile Application:
When you navigate through our LuxTrust Mobile Application, we may use different information for user authentication and collect device and analytics data through Google’s Firebase to help us to improve the application; additionally, we gather optional geo-location data to improve the user experience and security.

Processing purposes

We will process your personal data on the basis of one or more of the following:

  • the processing is necessary for the performance of a contract or for entering into a contract with you (e.g. by delivering you the ordered product or service);
  • the processing is necessary for us to comply with a legal or regulatory obligation;
  • the processing is necessary for our or a third party’s legitimate interests, for example: -when answering and managing any query from you; -providing you with the product, service or information requested; -sending you newsletter and other marketing email; -improving the quality of our services, our website and our LuxTrust Mobile Application and generally managing our relationship with our customers; -we may also combine the personal data collected with our data on your use of other LuxTrust services in order to make you offers which better suit your requirements.

Data disclosure

The personal data we collect shall not, in any circumstance, be passed on to third parties LuxTrust without your knowledge and/or consent (when such consent is legally required). To achieve the purposes described above, we may share with our sub-contractors, with our service providers which support us technically in the provision of our website and services, with public administrations and related bodies to the extent necessary for us to comply with any applicable laws and regulations. All of our employees and sub-contractors who have access to your personal data shall be obliged to keep it confidential and secure. They shall have access only to the data they require in order to perform their task or obligations, unless otherwise provided by laws or regulations.

Your rights

You have the following rights in relation to the processing of your personal data (subject to applicable requirements and exemptions):

  • right to access the personal data held about you and receive additional information about how it is processed;
  • right to rectify any inaccurate and incomplete personal data;
  • right to delete your personal data from our systems in certain circumstances, e.g. where the personal data is no longer necessary in relation to the specified purposes;
  • right to restrict the processing of your personal data in certain circumstances, e.g. where you contest its accuracy or object to processing;
  • right to receive your personal data in an interoperable format, or have it directly transmitted to another organisation;
  • right to withdraw your consent at any time where the processing is based on your consent to the processing of personal data;
  • right to object to the processing of your personal data, in certain circumstances and considering other regulatory requirements, in particular where we rely on legitimate interests; and
  • right to lodge a complaint with the Luxembourg Data Protection Authority (the Commission Nationale pour la Protection des Données).

To exercise these rights, you may make a request by contacting LuxTrust’s data protection officer at dpo@luxtrust.lu and/or LuxTrust’s data protection team at dpo@luxtrust.lu. To prevent fraud, LuxTrust reserves the right to carry out the necessary checks to verify your identity (for instance by asking you to authenticate using your LuxTrust products) when making a request to exercise a right. Data retention: We retain your personal data only for as long as necessary for the relevant processing activity and/or for as long as is necessary to comply with all relevant legal and regulatory requirements.

Security

We take all reasonable steps to protect your personal data collected when using this site and/ or the LuxTrust Mobile Application against loss, misuse, unauthorised access, disclosure, unauthorised alteration or unlawful destruction. Please note that Internet connections are never 100% secure or error-free. In particular, e-mails sent to or from this site may be corrupted. You should therefore take care when choosing the information you send us by e-mail. Furthermore, when you use passwords, ID numbers or other means of access on this site or in the LuxTrust Mobile Application, it shall be incumbent upon you to protect them.

Property

All of the content (photos, text, videos, etc.) available on the website and on the LuxTrust Mobile Application, as well as the services offered, are the exclusive property of LuxTrust and/or its partners. You may not reproduce, represent, market or use this content unless in circumstances permitted by law or duly authorised by LuxTrust.

Cookies and connection data: This website and the LuxTrust Mobile Application make use of Internet Protocol (IP) addresses and cookies. An IP address is a number assigned to your computer by your internet service provider, giving you access to the internet. Cookies: Cookies are small files created by a website which are then placed on your computer’s hard drive. Cookies used by this website or by the LuxTrust Mobile Application aim solely to ensure that you find this site and/or the LuxTrust Mobile Application as easy as possible to use. You may deactivate these cookies at any time; however, please be aware that the site may run at sub-optimal levels if you choose to do so. Details of the cookies we use are available under our Cookie Policy.

External links

This website may feature links to websites which are not managed by LuxTrust. These external links are for information purposes only. If you visit these websites, we recommend that you read their respective privacy policies carefully. We may not be held responsible for the confidentiality policies or content of these websites, or for the practices of their administrators.

Declaration

By using this website and/or the LuxTrust Mobile Application, you declare being informed of and bound by the provisions of the Privacy Policy for website and for the LuxTrust Mobile Application. When sending information via this site or via the LuxTrust Mobile Application, you acknowledge that your data will be collected, used and disclosed pursuant to the Privacy Policy for website and for the LuxTrust Mobile Application. Amendments: LuxTrust reserves the right to amend the Privacy Policy for website and for the LuxTrust Mobile Application. Any changes that we may make will be posted on this page and dated. The revised Privacy Policy for website and for LuxTrust Mobile Application will be effective immediately upon posting to our website. You accept to be bound by such amendments and should thus visit this page periodically so as to be aware of the provisions to which you are bound.

Contact information

For any question about the Privacy Policy for website and for LuxTrust Mobile Application, you may contact our Data Protection Officer at: dpo@luxtrust.lu.

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