Privacy Policy

1. Introduction

This Privacy Policy informs users of this website about the conditions under which their personal data is collected, used and protected by LUXCOMPLY, in accordance with Regulation (EU) 2016/679 (General Data Protection Regulation – “GDPR”) and the Luxembourg Law of 1 August 2018 on the organisation of the National Commission for Data Protection and the general data protection framework.

This Policy applies exclusively to data collected through this website. The processing of personal data carried out in the context of LUXCOMPLY’s commercial relationships with its clients and prospects is governed by separate contractual and information documentation.

2. Data Controller

The data controller is:

LUXCOMPLY SARL
177, Rue de Luxembourg, 8077 Bertrange, Luxembourg
RCS Luxembourg: B290710
Email: contact@luxcomply.com
Telephone: +352 20 60 58 57
Represented by: Ibrahim Hourfane

For any question relating to this Privacy Policy or the exercise of your rights, you may contact us at the above details.

3. Data Collected

a) Browsing Data (Analytics)

This website uses Independent Analytics, a privacy-friendly audience measurement tool hosted directly on the website’s server. The data collected may include:

        •       Pages visited
        •       Referring websites or search engines
        •       Device type (desktop, tablet, mobile)
        •       Country or region (approximate location, based on anonymised IP address)
        •       Date and time of visit

This data is aggregated and does not allow direct identification of users.

b) Data Submitted Voluntarily

When users contact LUXCOMPLY by email or telephone, the information provided (name, email address, telephone number, content of the message, and any other information communicated) is collected solely for the purpose of responding to the request.

c) Cookies and Similar Technologies

This website uses:

        •       Strictly necessary cookies required for the technical operation of the website
        •       An audience measurement tool (Independent Analytics) configured in compliance with the exemption criteria recommended by data protection authorities (no cross-site tracking, anonymised IP, data not shared with third parties, retention limited in time).

No advertising, profiling or marketing cookies are used.

For further information, please refer to our Cookie Policy.

4. Purposes of Processing

Personal data is processed for the following purposes:

        •       Statistical analysis of website traffic and usage
        •       Improvement of the website’s content, security and services
        •       Responding to requests submitted by email or telephone
        •       Compliance with LUXCOMPLY’s legal and regulatory obligations

5. Legal Basis for Processing

Processing activities are based on the following legal bases (Article 6 GDPR) :

        •       Legitimate interest (Art. 6(1)(f)) for the analysis of website traffic and the security and improvement of the website, where the audience measurement tool benefits from the consent exemption applicable to strictly necessary measurement tools
        •       Pre-contractual measures or legitimate interest (Art. 6(1)(b) or (f)) when responding to requests submitted via email or telephone
        •       Compliance with a legal obligation (Art. 6(1)(c)) where applicable

Where applicable cookies fall outside the consent exemption, processing will be based on the user’s prior consent (Art. 6(1)(a) GDPR and Article 2 of the Luxembourg Law of 30 May 2005), which may be withdrawn at any time.

6. Data Retention

   •       Aggregated audience measurement data: maximum 13 months
   •       Information voluntarily provided (email/telephone) : retained for the time necessary to handle the request and, where applicable, for the duration of the subsequent relationship, plus the applicable legal limitation periods
   •       Server logs: retained for a maximum of 12 months for security and fraud prevention purposes

7. Recipients of Data

Personal data is intended exclusively for LUXCOMPLY’s authorised personnel and, where applicable, for its technical service providers acting as processors (hosting, maintenance, IT administration), strictly to the extent necessary for the performance of their services.

LUXCOMPLY does not sell personal data and does not transfer it to third parties for commercial purposes

8. Transfers Outside the European Union

Personal data collected through this website is hosted within the European Union (France, o2switch). No transfer of personal data outside the European Economic Area is carried out.

Should such a transfer become necessary in the future, it would be governed by the appropriate safeguards provided for in Chapter V of the GDPR (Standard Contractual Clauses, adequacy decision, etc.).

9. Automated Decision-Making

LUXCOMPLY does not carry out any automated decision-making, including profiling, producing legal effects or similarly significantly affecting users within the meaning of Article 22 GDPR.

10. Security

LUXCOMPLY implements appropriate technical and organisational measures to ensure a level of security appropriate to the risk, in particular against unauthorised access, loss, alteration or disclosure of personal data.

11. Users’ Rights

In accordance with Articles 15 to 22 GDPR, users have the following rights:

        •       Right of access
        •       Right to rectification
        •       Right to erasure (“right to be forgotten”)
        •       Right to restriction of processing
        •       Right to object
        •       Right to data portability
        •       Right to withdraw consent at any time, where processing is based on consent (without affecting the lawfulness of processing carried out before such withdrawal)
        •       Right to give instructions regarding the fate of their data after their death

These rights may be exercised by sending a request to contact@luxcomply.com, accompanied where necessary by any element allowing the identity of the requester to be verified.

LUXCOMPLY undertakes to respond within one (1) month of receipt of the request, a period which may be extended by two (2) months depending on the complexity and number of requests, in accordance with Article 12(3) GDPR.

12. Complaint to the CNPD

Without prejudice to any other administrative or judicial remedy, users have the right to lodge a complaint with the Luxembourg supervisory authority:

Commission Nationale pour la Protection des Données (CNPD)
15, Boulevard du Jazz, L-4370 Belvaux
Telephone: (+352) 26 10 60 -1
Website: www.cnpd.lu

13. Changes to this Policy

This Privacy Policy may be amended at any time, in particular to reflect changes in the applicable legal and regulatory framework or in LUXCOMPLY’s processing activities. The applicable version is the one published on this website on the date of consultation. Users are invited to consult it regularly.