1. WHO IS ACCOUNTABLE FOR PROCESSING MY PERSONAL DATA?
Majorel Group Luxembourg S.A.
43, boulevard Pierre Frieden
Email : firstname.lastname@example.org
is responsible for processing your personal data on this website (hereinafter referred to as “we”).
We process personally identifiable information (“personal data”) in accordance with GDPR provisions.
You can contact our designated Data Protection Officer at the address indicated above by using the reference ‘For the attention of the Data Protection Officer’ or by writing to email@example.com with the subject line ‘For the attention of the Data Protection Officer’.
2. WHAT DATA IS COLLECTED?
When you visit our website, the data of the computer you use to access our website is automatically logged (“access data”). This access data includes server log files that generally consist of information pertaining to your web browser type and version, your operating system, your internet service provider (ISP), the date and time you used the website, the websites previously visited by you and the websites you accessed from our website, in addition to the IP address of your computer. With the exception of your IP address, the information contained in the server log files is not personally identifiable. An IP address is personally identifiable when it is static (permanently allocated when using internet access) and the ISP is able to attribute it to a specific person.
Some features of our website require that you divulge personal information to us. In this case, the information provided by you is used to provide the service requested by you or process a matter submitted by you (e.g. search queries, entries made in forms or contracts, click data). Other services on this website will require you to provide information such as your first and last name, email address and phone number. These are required in cases you wish us to contact you back.
3. WHAT COOKIES ARE USED?
As a general principle, cookies enable online recognition without reference to a specific person. Cookies may become personally identifiable when the information they contain is merged with other information apart from the information generated by the cookies themselves.
Depending on their function and purpose, the cookies we use can be divided into the following categories:
4. WHAT PERSONAL DATA IS COLLECTED AND FOR WHAT PURPOSE?
The purpose of data processing may be based on technical, contractual or statutory requirements or result from consent having been given by the user.
We use the data described in section 2 for the following purposes:
4.1 PROVISION OF THE WEBSITE
4.1.1 DESCRIPTION AND SCOPE OF DATA PROCESSING
In order to enable the proper functioning of our website, security analyses to be conducted, and denial-of-service attacks to be prevented and stopped, server log files are automatically collected and saved on a short-term basis as an integral part of access data that is created by the system of the visiting computer upon accessing our website and while using it (see section 2). The content of the server log files is not merged with other data. We use the server log files for statistical analyses to troubleshoot and remedy technical issues, prevent and defend against denial-of-service attacks and attempted fraud, and to optimize the proper functioning of our website.
4.1.2 PURPOSE AND LEGAL BASIS OF DATA PROCESSING
The legal basis for the creation of server log files follows from Art. 6 para. 1 lit. f GDPR. Our legitimate interests lie in the proper functioning of our website, conducting security analyses and defending against threats.
4.1.3 DURATION OF STORAGE OR CRITERIA APPLIED IN DEFINING THIS PERIOD
When the pages of our website are accessed, information is logged to server log files that are stored on our web server; the IP address contained in them is deleted after 7 days at the latest. No analysis is conducted during this time unless there is a denial of service or other attack.
4.1.4 OPTIONS FOR LODGING AN OBJECTION AND HAVING YOUR DATA REMOVED
You have the right to lodge an objection to the processing of your data contained in the server log files provided that there are cogent reasons that arise from your specific situation. If you would like to exercise your right to lodge an objection, please write to the contact address in section 1.
4.2 CONTACT FORM, EMAIL, CHATBOT AND TELEPHONE CONTACT INFORMATION
4.2.1 DESCRIPTION AND SCOPE OF DATA PROCESSING
On our website you have the option of contacting us by way of a contact form, by email, by telephone or by chatbot using the designated email address and phone number. If you take advantage of this option, the information you enter in the contact form, your email address and/or your phone number are disclosed to us and stored in a dedicated database. Depending on the reason you are contacting us (questions about our products and services, pursuing your rights as a data subject, e.g. submitting a request for information) your contact details are processed (with the assistance of service providers). If necessary for processing your request, this information may be shared with third parties (e.g. partner companies).
4.2.2 PURPOSE AND LEGAL BASIS OF DATA PROCESSING
The legal basis for processing your contact details follows from Art. 6 para. 1 lit. f GDPR. We have legitimate interests in processing your request and in continued communication. If the purpose for your establishing contact with us is to enter into a contract with our company, the legal basis for processing your contact details follows from Art. 6 para. 1 lit. b GDPR.
4.2.3 DURATION OF STORAGE OR CRITERIA APPLIED IN DEFINING THIS PERIOD
Your contact details are deleted once your request has been processed and further communication has been discontinued. This does apply if the purpose of your establishing contact with us is to conclude a contract or you wish to exercise your right as a data subject (e.g. request information). In this case your details are stored until all contractual and/or statutory obligations have been fulfilled and statutory retention periods (currently 6 to 10 years) do not prevent this information from being deleted.
4.2.4 OPTIONS FOR LODGING AN OBJECTION AND HAVING YOUR DATA REMOVED
You have the right to lodge an objection to the processing of your contact information provided that there are cogent reasons that arise from your specific situation. If you would like to exercise your right to lodge an objection, please write to the contact address in section 1. If you lodge an objection, communication with you cannot be continued. This does not apply if the storage of your contact details is necessary for completing precontractual procedures, fulfilling a contract or exercising your rights as a data subject.
4.3 ASSERTING YOUR RIGHTS AS A DATA SUBJECT
4.3.1 DESCRIPTION AND SCOPE OF DATA PROCESSING
On the website you have the possibility of asserting your rights as a data subject, e.g. request information on your personal information that is currently stored by us in relation to your visit of the website. In order to assert your rights as a data subject, it may be necessary that you provide us information pertaining to your person and the specific information that has been processed. Without providing this information, we are not able to cater to your rights as a data subject.
4.3.2 PURPOSE AND LEGAL BASIS OF DATA PROCESSING
The legal basis for processing your personal information in asserting your rights as a data subject follows from Art. 6 para. 1 lit. c GDPR, “Complying with a legal obligation”.
4.3.3 DURATION OF STORAGE OR CRITERIA APPLIED IN DEFINING THIS PERIOD
We store the correspondence exchanged with you in relation to your asserting your rights as a data subject for a period of three years. This does not apply to information obtained to clarify your identity, e.g. by way of a labeled photocopy of your personal identity card, where we have been provided one. It will be deleted within one week at the latest of establishing your identity.
4.3.4 OPTIONS FOR LODGING AN OBJECTION AND HAVING YOUR INFORMATION REMOVED
The processing of your information is required for complying with your rights as a data subject, and to that extent you have no right to revoke your consent to its processing.
4.4 STUDIES, REPORTS AND WHITEPAPERS
4.4.1 DESCRIPTION AND SCOPE OF DATA PROCESSING
4.4.2 PURPOSE AND LEGAL BASIS OF DATA PROCESSING
Processing the information entered by you in the registration form is necessary for advertising pertaining to products and/or services provided by us. The legal basis for this is your consent pursuant to Art. 6 para. 1 lit. a GDPR.
4.4.3 DURATION OF STORAGE OR CRITERIA APPLIED IN DEFINING THIS PERIOD
Your information is stored to show proof that we obtained your consent for sending you Majorel’s free studies, reports and whitepapers. The same applies if you have revoked your consent.
4.4.4 OPTIONS FOR LODGING AN OBJECTION AND HAVING YOUR DATA REMOVED
You can revoke your consent to receiving press releases at any time by writing to Majorel Group Luxembourg S.A. (43, boulevard Pierre Frieden, L-1543 Luxembourg, Email: firstname.lastname@example.org with the subject line ‘Remove from studies reports and whitepapers’ ).
The website contains services that optimize user-friendliness and measure the reach of the website. Your access data (see section 2) is recorded and with the help of cookies (see section 3), the usage behavior is evaluated. In principle, personal identification is not required for web tracking, so that when your access data is entered, the stored IP address is either not used or is used exclusively shortened (shortened by the last octet) and pseudonymous user profiles are created. In principle, these are not merged with other data and you have the possibility of withdrawal at any time. The creation of personal user profiles takes place exclusively in exceptional cases and provided that you have given your consent.
The legal basis for collecting and analyzing pseudonym usage profiles follows from Art. 6 para. 1 lit. f GDPR / Section 15(3) German Telemedia Act (TMG). We have a legitimate interest in optimizing the user-friendliness of our website and performing marketing reach measurements.
The data collected and evaluated when using the web tracking services is usually stored until you object to their use.
4.8 EXTERNAL SERVICES AND CONTENT ON OUR WEBSITE
We integrate external services and content on our website. If you use one of these services or you are shown the content of third parties, communication data is exchanged between you and the provider of that service or content for technical purposes.
That provider may use your data for their own purpose. To the best of our knowledge and belief, we have configured the services or content of third-party providers who are known to use data for their own purposes so that communication for purposes other than rendering their content or services on our website is prevented or communication does not come about unless you actively decide to use the service. However, since we have no control over the data collected by third parties and its processing by them we are unable to make any binding statements pertaining to the purpose and scope of the processing of your data.
5. WHO COMES INTO POSSESSION OF MY PERSONAL DATA?
Within our company those who need access to your information for the purposes described in section 4 will be given access to it. Service providers contracted by us may also be given access to your information (“contract data processors”, e.g. data centers, mailing services for newsletters, web tracking). They are bound by our directives and must provide for data security and the confidential treatment of your information under the contract data processing agreements we have concluded with them.
No sharing of information with other recipients such as advertising partners, providers of social media services or credit institutions (“third parties”) takes place.
6. IS MY PERSONAL DATA PROCESSED OUTSIDE OF THE EU OR EEA (‘TRANSFER TO A THIRD COUNTRY’)?
The use of Google Analytics as described in section 3.3. above causes personal data to be transferred to a third country since the data centers of Google Inc. are located outside of the European Union and the European Economic Area (“EU or EEA”). Such transfers of personal data to third countries may result in your personal information being transmitted to a country which does not provide for the same standard of data protection as the EU or EEA. For this case, respective EU Standard Contractual Clauses have been signed. You can request a copy of these safeguards by contacting the addresses indicated in section 1 above.
7. WHAT DATA PRIVACY RIGHTS DO I HAVE?
You have the right to request access to your personal data that is currently stored by us. If this data is incorrect or not up to date, you have the right to request rectification. You also have the right to have your personal data erased and/or its processing restricted as provided for in Art. 17 and Art. 18 GDPR. You also have the right to request a copy of the personal data provided by you in a structured, commonly-used, machine-readable format (right to data portability).
If you have given your consent to the processing of your personal information for specific purposes, you can withdraw that consent at any time for the future. Your notice of revocation is to be addressed to us by writing to the contact address indicated in section 1.
Pursuant to Art. 21 GDPR, you also have the right for reasons relating to your specific situation to raise an objection to the processing of your data that is done on the basis of Art. 6 para.1 lit.f GDPR. You also have the right to lodge an objection to the processing of your personal information for direct marketing purposes. The same applies to automated processes involving the use of individual cookies, unless they are required for providing the functionality of our website.
You also have the right to lodge a complaint with the competent data protection authority. The authority responsible for us is:
Commission nationale pour la protection des données
1, avenue du Rock’n’Roll
Telefon: +352 26 10 60-1
You also have the right to contact the data protection authority at your place of residence and request support in pursuing your matter.
8. TO WHAT EXTENT DOES AUTOMATED DECISION-MAKING TAKE PLACE?
We do not use any fully automated decision-making processes for any of the purposes set out in section 4.
9. IS PROFILING DONE?
No profiling takes place for any of the purposes set out in section 4.
10. HOW WE PROTECT YOUR PERSONAL DATA?
We take technical and organizational measures to protect your personal data and keep it confidential. We take extensive technical and organizational security measures, which are regularly reviewed and adapted to technological progress, to prevent manipulation or loss or misuse of your personal data. This includes, among other things, the use of recognized encryption methods (SSL or TLS). However, we would like to point out that, due to the structure of the Internet, it is possible that the rules of data protection and the above-mentioned security measures are not observed by other persons or institutions that are not in our area of responsibility. In particular, data disclosed in unencrypted form – e.g. if this is done by e-mail – can be read by third parties. We have no technical influence on this. It is the user’s responsibility to protect the data he or she provides against misuse by encrypting it or in any other way.