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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:



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 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


Purpose of processing 

Legal basis 

Creation, management of the user account 

Performance of a contract or pre-contractual measures (Article 6.1.b of the GDPR) 

Securing the user account 

Legitimate interest of Streff (Article 6.1.f of the GDPR) 

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:



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.