Legal notice

Privacy statement

Streff - Data Protection Services (PSF) S.à r.l. and Albert Streff S.à.r.l. et Cie SECS (hereinafter “Streff” or “we”), as data controllers, attach the utmost importance to respecting your privacy and are committed to processing your personal data in accordance with the applicable legislation on the processing of personal data and, in particular, Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (hereinafter “GDPR”) and the law of 1 August 2018 establishing the National Commission for Data Protection and the general data protection regime.

A Data Protection Officer (“DPO”) has been appointed by Streff and can be contacted for any questions relating to the processing of personal data:

• by email at [datenschutz@streff.lu](mailto:datenschutz@streff.lu)
• By post: 138 Rte d'Arlon, 8008 Strassen, Luxembourg

SCOPE OF THE POLICY

This privacy policy explains how we collect and use personal data through our website.

As a general rule, it is possible to access and browse this website without having to disclose any information or personal data. However, personal data may be collected when you contact us via our contact form or when you opt for certain types of cookies. Data may also be collected when accessing or using the client portal.

PROCESSING OF DATA TRANSMITTED VIA THE CONTACT FORM

Purposes and legal basis of processing

Anyone can contact Streff through the contact form available on its website. In this context, the processing of personal data is based on consent (Article 6.1.a of the General Data Protection Regulation).

Categories of data collected

The data collected through the contact form are mainly:

• identification data (surname, first name);
• contact data (email address, telephone number, postal address);
• communication language;
• any other category of personal data contained in the message sent.

The contact form contains a "message" field in which you can formulate your request. It is advisable to mention only the information necessary to process your request and, in particular, to avoid including, unless absolutely necessary, sensitive data (within the meaning of Article 9 of the General Data Protection Regulation) concerning yourself or a third party (for example, data relating to health, political opinions, or religious beliefs).

Recipients of the data

The data we collect are processed in strict confidence and are only shared with third parties when necessary and in accordance with the law. These third parties may include our service providers, particularly in the context of IT subcontracting. In the latter case, we ensure that your data remain within the European Union or in countries offering a similar level of protection.

Data retention periods

The data collected in order to respond to your contact requests are kept for 2 years from the last contact with you or closure of your request.

Your rights

In accordance with the law, you have the following rights:

• The right to information. We hope this notice has answered your questions.
• The right to free access to your data.
• The right to rectify your data when they are incorrect or outdated.
• The right to withdraw your consent at any time.
• The right to lodge a complaint with the National Commission for Data Protection (CNPD) if you believe that the processing of your data does not comply with the law.

In certain cases and under the conditions set by law, you also benefit from the following rights:

• The right to request erasure of your data.
• The right to request restriction of processing of your data.
• The right to object to the processing of your data for legitimate reasons.

You can therefore unsubscribe from our newsletters at any time, using the unsubscribe link found in each newsletter.

The right to data portability of the data you have provided to us (i.e. the right to receive your personal data in a machine-readable format), insofar as this is technically possible.

Contact

For any questions regarding the processing of your data or to exercise your rights, you can contact the Foundation’s DPO:

• By email: [datenschutz@streff.lu](mailto:datenschutz@streff.lu)

• By post: 138 Rte d'Arlon, 8008 Strassen, Luxembourg

In order to comply as best as possible with the regulations in force, we undertake to update this information notice whenever necessary.

DATA PROCESSING IN THE USE OF THE CLIENT PORTAL

Purposes and legal bases of processing

Categories of data collected

The following data may be collected when using the client portal:

• Identification data: surname, first name, email address, telephone number;
• Login credentials: username, password (encrypted);
• Data related to use of the service: connection history, requests or actions performed on the portal;
• Any other data necessary for the operation of the services offered via the portal.

Recipients of the data

The data we collect are processed in strict confidence and are only shared with third parties when necessary and in accordance with the law. Your data are exclusively accessible by authorized internal services as well as, where applicable, by our technical service providers acting as subcontractors. These third parties are bound by a duty of confidentiality and act only on our instructions.

Data retention periods

Data relating to your client account are retained for the entire duration of use of your account. In the event of prolonged inactivity, the account may be deactivated in accordance with our policy on the management of inactive accounts.

Your rights

In accordance with the law, you have the following rights:

• The right to information. We hope this notice has answered your questions.
• The right to free access to your data.
• The right to rectify your data when they are incorrect or outdated.
• The right to withdraw your consent at any time.
• The right to lodge a complaint with the National Commission for Data Protection (CNPD) if you believe that the processing of your data does not comply with the law.
• In certain cases and under the conditions set by law, you also benefit from the following rights:
• The right to request erasure of your data.
• The right to request restriction of processing of your data.
• The right to object to the processing of your data for legitimate reasons.

You can therefore unsubscribe from our newsletters at any time, using the unsubscribe link found in each newsletter.

The right to data portability of the data you have provided to us (i.e. the right to receive your personal data in a machine-readable format), insofar as this is technically possible.

Contact

For any questions regarding the processing of your data or to exercise your rights, you can contact the Foundation’s DPO:

• By email: [datenschutz@streff.lu](mailto:datenschutz@streff.lu)
• By post: 138 Rte d'Arlon, 8008 Strassen, Luxembourg

In order to comply as best as possible with the regulations in force, we undertake to update this information notice whenever necessary.

COOKIES AND OTHER TRACKERS

Among the data collected through our website are data resulting from the placement of cookies. Users of this website acknowledge that they have been informed of the possibility to change their consent at any time via the banner settings on the website.

For more information, please consult our cookie management policy.

Legal Notice

1. Website publisher and owner

This website ("website") and its content are the property of STREFF Group formed by Streff Data Protection Services (PSF), having its registered office at L-8399 Windhof, 5 rue Pierre Flammang, registered in the Luxembourg Trade and Companies Register. under number B11477, and Albert Streff Sàrl et Cie SECS having its registered office at L-8008 Strassen, 138, rte d'Arlon, (the “Company”).

If the user notices an anomaly or encounters problems on the website, the user is invited to inform: service@streff.lu

Hosting provider

This website is hosted in Luxembourg with Odoo.

2. Website terms of use

By browsing the website, the user unreservedly accepts the conditions of use of the website set out below.

The user agrees to use the website with due diligence, not to infringe the rights of the Company, its customers, or any third party, and not to prejudice them.

The user undertakes, in particular, not to damage the reputation, defame, abuse, harass, or threaten the Company, a client thereof, or a third party, and not to use any sub-program, software, or any other device of whatever nature that could affect the proper functioning of the website.

The Company reserves the right to modify these conditions of use of the website at any time. Use of the website after modification of the Terms of Use constitutes unreserved acceptance of the new Terms of Use for the website. Therefore, the Company advises all users to regularly consult the Terms of Use of the website.

3. Purpose of the website

The purpose of the website is to present the products and services of the Company.

4. Intellectual property

The website as well as its content and components are the intellectual property of the Company.

The website and its content are owned and operated by the Company. Without limitation, texts, photographs, publications, documents to download or any other creation or original document are protected by copyright and their publication on the website does not in any way constitute a concession of rights of use, a license or any authorization, except in the case of the express, prior and written authorization of the Company.

Any use, distribution, copy, reproduction, representation, translation, adaptation, or quotation, whether complete or partial, whatever the process of the website, its content or its components is strictly prohibited except in the event of express, prior and written authorization of the Company.

5. Access to the website

The Company ensures the availability of the website. However, the Company cannot be held responsible for the temporary unavailability of the website due to maintenance or improvements, or for other technical reasons. The Company reserves the right to deny the user access to the website at any time and without notice.

6. Non-engagement

The website, it’s content and its components are regularly updated to allow access and use in the best conditions. However, the Company cannot guarantee the topicality, completeness, accuracy, and completeness of the content of the website in real-time.

The content of the website is provided for informational purposes only.

The website was developed in a technical environment chosen by the Company and is regularly updated to ensure its accessibility. However, the Company does not guarantee, under any circumstances, either permanent accessibility or the absence of errors.

Each user encountering difficulty while browsing is invited to inform the Company by contacting service@streff.lu

The Company cannot be held responsible for any inconvenience and / or damage caused to a user by the actions of a third party who, by unfair technical means, a virus or malware, has used the information published on the website. However, the Company implement means to fight against any external attack or harmful action by third parties, being however limited by the constraints and risks inherent on the Internet.

The Company cannot be held liable for any damage suffered, particularly because of the quality of the user's computer equipment, the quality of the Internet network and/or the technical configurations available to the user. The Company cannot be held responsible for a malfunction or deterioration of a module external to the website.

The Company reserves the right to pursue any person who has harmed the website through any means, including its technical structure, content, or components (such as illegal copying, hacking, or the sending of malicious files).

7. Processing of personal data

When the user accesses or uses the website, the Company may collect and process personal data in accordance with applicable data protection law, including the GDPR. For more information on how we process personal data, please refer to our Data Protection statement.

The Company uses cookies to collect and record certain information from users when they visit the website.  For more information, please refer to our Cookie Policy.

8. Links to other websites

The website may contain links to external websites that may be of interest to the user. The Company cannot be held responsible for the content of any third-party websites to which users have access via this website.

The Company has no means of controlling the content of these third-party sites, which remain independent from the Company.

In addition, the existence of a link between the website and a third-party site does not in any way mean that the Company approves in any capacity whatsoever the content of this site and a fortiori the use that may be made of it.

The Company encourages users to be aware of the policies, rules, terms, conditions of use, and regulations of each site they visit.

9. Applicable law and competent court

Any dispute relating to the website, its consultation, or its use by the user will be subject to Luxembourg law and will fall under the jurisdiction of the Luxembourg court.

10. Contact

The user can contact service@streff.lu for any inquiries.

Processing of personal data and cookies

The Company uses cookies to collect and record certain information from users when they visit the website.

For more information about the use of cookies click here