Under this privacy notice (hereinafter the “Notice”), LuxCSD (hereinafter “We” or “Us”) informs you how We process your personal data. Your personal data means any information relating to you (hereinafter the “Personal Data”), such as name or contact details.
We pay special attention on the processing of Personal Data in accordance with the General Data Protection Regulation EU 2016/679 (“GDPR”) and applicable national data protection laws.
1.1. Our identity and contact details
42, avenue JF Kennedy
1.2. Contact details of data protection officer
Data Protection Officer
42 Avenue JF Kennedy
or send an email to: firstname.lastname@example.org
2. Purpose, Categories of Personal Data, Legal Basis and Retention
2.1. Categories of your personal data, purposes of our processing and their legal basis
We process the following categories of your Personal Data for the following purposes:
2.1.1 General contact by e-mail, post or telephone: Name, address, telephone number or e-mail address if you wish to contact us directly. We collect your personal data when you provide it to us via our contact forms or when you contact us directly. Then we process the information that you have provided to us in the course of establishing contact. This includes, in particular, names and contact data provided (address, telephone number or e-mail address), date and reason for contact. The personal data that you collect will only be used to answer and fulfil your specific enquiries. The legal basis is Art. 6 para. 1 lit. (f) GDPR, which permits the processing of personal data for the purpose of our legitimate interest in processing and answering your enquiry. Your personal data processed in this respect will be stored by us for as long as it is necessary to carry out our relationship (communication) with you and in accordance with the applicable legal storage regulations.
2.1.2 Newsletter: LuxCSD S.A. offers newsletters to keep you regularly informed about ongoing initiatives and upcoming projects and any future updates or news about products and events. You can register if you would like to subscribe to on our website by entering your email address. After entering your data, you will receive an e-mail in which you can confirm your registration in order to activate the newsletter. You can unsubscribe from this service in every newsletter and withdraw your consent with effect for the future. With regard to the processing of your personal data, the relevant legal basis is your consent in accordance with Article 6 para. 1 lit. (a) in connection with Article 7 GDPR.
2.1.3 Sales, Marketing and invitations: We may use your personal data (name, first name, address, company, telephone number, e-mail address) to send you information about our services, partners, promotions and events that we think may be of interest to you. We may contact you by e-mail based on our legitimate interests under Article 6 para. 1 lit. (f) of the GDPR if we have a direct business relationship with you or with the company for which you work, and if you have not objected. We may contact you by telephone if you have given your consent (Article 6 para. 1 lit. (a) GDPR) or on the basis of a presumed consent on the condition that you will welcome the call. We may contact you by post on the basis of our legitimate interests under Article 6 para. 1 lit. (f) GDPR as long as you do not object. In such cases, it is our legitimate interest to inform business partners or potential customers about such services and products that may be of interest to them and thus to maintain our existing or future business relationship. Your personal data processed in this respect will be stored by us for as long as it is necessary to carry out our relationship (communication) with you and in accordance with the applicable legal storage regulations.
2.1.4 Applications: Data protection information on the application process can be found directly in the privacy notice on our careers page.
2.1.5 Performance of contracts and services: If you or your company want to be authorized as a customer of one of our services, we collect your personal data (first name, last name, contact data, company address, payment details) to register you to our service and for the usage of our service. The purposes of personal data processing are determined by the specific service or product. This may include issuance, settlement, asset services, investment fund services, connectivity, market coverage and Legal Entity Identifier service. The legal basis for processing this personal data is Article 6 (1) lit. b GDPR, as processing is necessary to fulfil a contract or for pre-contractual measures between us and the customer. If the user is not the customer who concluded the contract with us, but an employee of the customer or otherwise authorized by the customer to use our services, the legal basis for processing is Article 6 (1) lit. f GDPR, as the processing is in the legitimate interest of the customer. The legitimate interest of the customer is to enable the user to use our services in accordance with the contract. Your personal data processed in this regard will be stored by Us as long as it is necessary to carry out Our relationship (registration and use of our service) with you and required by applicable statutory retention laws.
2.1.6 General use of our website: When you use our website and online platform, we will automatically log information about the browser that is used to access the website, such as your IP address, session time, pages viewed from that address and the website from which you are visiting the website. We may also collect device-specific information, such as your hardware model and operating system. We use this information to identify and prevent malpractice and crime and to investigate improper conduct. The legal basis for the processing of your personal data for these purposes is Art. 6 para. 1 lit. (c) GDPR in fulfilling our legal obligation to take technical and organisational measures to ensure secure data processing in accordance with Article 32 GDPR and Article 6 para. 1 lit. (f) GDPR in order to pursue our legitimate interests in data processing for network and information security. After the specified period of 30 days, the above data will be deleted. If data is processed for a longer period of time, we will anonymise or delete the data as soon as their storage no longer serves the respective purposes.
2.2. Do you have to provide your Personal Data to Us?
The provision of your Personal Data is necessary to access the protected areas of this website which is limited to members of Our customer groups, to make direct contact with us, or to receive a newsletter. This means that you are obliged to provide your Personal Data to Us as part of a user registration process when making use of these options. Such Personal Data remain under your control at all times via the “My Profile” facility. Your user account can be viewed or modified at any time by you, the account owner.
The consequences if you do not provide your Personal Data to Us are that the respective service offered may no longer be available.
2.3. Do We make automated decisions on you?
We do not make any automated decisions solely on automatic processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
2.4. Retention periods
The retention periods for personal data depend on the purpose of the processing. We will store the personal data mentioned under 2.1 above as long as (i) this is necessary for the respective purpose and / or (ii) this is required in accordance with the applicable statutory retention laws. We will keep personal data that you provide us for as long as our business relationship with you or with your company exists, plus all applicable retention periods that are in accordance with the statutory provisions (e.g. based on tax regulations) or to the extent they are necessary to pursue our legitimate interests after the end of the business relationship (e.g. to assert claims within the statutory limitation periods).
3. Transfer of Personal Data to Third Parties
We will not disclose your personal data to third parties unless such disclosure is permitted by law or you have explicitly consented to the transfer.
To provide our contractual services, we use selected service providers (data processing providers) and vicarious agents of the categories listed below who have access to your personal data to the extent necessary and can use it to process the orders placed by us.
We may transfer your personal data to public authorities where this is required by applicable law. A transfer of your personal data is also permitted if there is suspicion of a criminal offence or the abuse of the services offered on our website. In this event, we shall be entitled to transfer your Personal Data to the criminal prosecution authority.
Otherwise, your personal data will be stored exclusively in our database and on our servers or on those of our commissioned data processing providers. We will only share your Personal Data with other controllers for their own purposes such as cooperation or advertising partners under the condition that you explicitly and voluntarily agreed to such transfer of your Personal Data; in this case, we will obtain your consent separately from this Notice.
Sometimes the recipients to whom we transfer your personal data are located in countries in which applicable laws do not offer the same level of data protection as the laws of your home country. In such cases, we take measures to implement appropriate and suitable safeguards for the protection of your personal data.
Under these conditions, recipients of your personal data can be for example:
- public bodies and institutions in the presence of a legal or regulatory obligation (e.g. financial authorities),
- other companies and service providers (processors) / vicarious agents in the following areas:
- print service providers
- telecommunications service provider
- billing service provider
- financial institutions
- collection agencies
- management consultancies as well as business and tax audit companies
- provider of the online platform
- newsletter provider
4. Cookies and similar technologies
When you visit the website and Our online platform, information is stored on your terminal device in the form of a "cookie." Cookies are small files that are stored on your terminal device and save certain settings and data to exchange with our websites via your browser.
For example, cookies enable us to tailor a website to better match your interests or to store your password so that you do not have to re-enter it every time. As a general rule, we never collect personal data via cookies, unless you have given us your express permission to do so.
If you do not want us to recognize your terminal device, please configure your Internet browser to erase all cookies from your device, to block all cookies or to receive a warning before a cookie is stored. You will find brief instructions on how to do this below.
Please note that certain functions of our website may no longer work, or not correctly, without cookies.
a. Types of cookies
Cookies can be assigned to four categories, depending on their function and intended purpose: absolutely necessary cookies, performance cookies, functional cookies, and cookies for marketing purposes.
i. Absolutely necessary cookies
Are needed for you to navigate within websites and operate basic website functions, such as the issuance of anonymous Session IDs for bundling several related queries to a server.
ii. Performance cookies
collect information on the usage of our websites, including for example the Internet browsers and operating systems used, the domain name of the website which you previously visited, the number of visits, average duration of visit, and pages called up. These cookies do not store any information that would make it possible to personally identify the user. The information collected with the aid of these cookies is aggregated and is therefore anonymous. Performance cookies serve the purpose of improving the user friendliness of a website and therefore enhancing the user’s experience. You can block the use of such cookies by creating an exclusion cookie (see “managing cookies” below).
iii. Functional cookies
enable a website to store information the user has already entered (such as user ID, language selection, or the user’s location), in order to offer improved, personalized functions to the user. Functional cookies are also used to enable requested functions such as playing videos and to make a user’s decision to block or disable a certain function (e.g. web analysis) - “opt-out cookies”.
iv. Cookies for marketing purposes
are used to offer more relevant content to users, based on their specific interests. They are also used to limit the display frequency of an ad and to measure and control the effectiveness of advertising campaigns. They register whether users have visited a website or not, and which contents were used. This information may possibly also be shared with third parties, such as advertisers, for example. These cookies are often linked to the functions of third-party websites. You can block the use of such cookies by creating an opt-out cookie (see “Managing cookies” below).
b. Cookies on Our website and Our online platform
Please note: Not all of the cookies mentioned above will necessarily be used when you browse our website using a mobile terminal device.
c. Managing cookies
You can change your cookie preferences at any time by clicking on the ‘Cookies Preference Manager’ link. You can then adjust the available sliders to ‘On’ or ‘Off’, then clicking ‘Save and close’. You may need to refresh your page for your settings to take effect.
d. How can I deactivate cookies?
In the following you will find a summary of links that provide detailed information on the deactivation of cookies in commonly used browsers.
Mozilla Firefox (https://support.mozilla.org/en-US/kb/delete-cookies-remove-info-websites-stored)
Internet Explorer (https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies)
Google Chrome (https://support.google.com/accounts/answer/61416?hl=en)
5. Google Analytics
Google will use the information on our behalf to for example evaluate the use of our online offer by users and to compile reports on the activities within this online offer. Pseudonymous user profiles can be created from the processed data.
We use Google Analytics only with IP anonymisation enabled. This means that Google will shorten the IP address of users within Member States of the European Union or in other states party to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there.
The IP address transmitted by the user's browser is not merged with other Google data. Users can prevent the storage of cookies by setting their browser software accordingly; users can also prevent Google from collecting the data generated by the cookie and relating to their use of the online offer and the processing of this data by Google by downloading and installing the browser plug-in available under the following link: http://tools.google.com/dlpage/gaoptout?hl=en.
Further information on data use by Google, possible settings and objections can be found in Google's data protection declaration (https://policies.google.com/technologies/ads) and in the settings for the display of advertisements by Google (https://adssettings.google.com/authenticated).
Users' personal data will be deleted or made anonymous after 14 months.
6. Webtrends Analytics
Webtrends stores information about the pages you visit on our website, how long you spend on each page, how you got to the site, and how many times you have accessed our site.
Webtrends deletes client data, including backups, within ninety (90) days following termination of the agreement. Webtrends leverages data collection centers in Australia, Netherlands, and the United States. All data is processed and stored in the United States.
You can opt out of receiving cookies from Webtrends by following the instructions at: https://ondemand.webtrends.com/support/optout.asp.
For more information, please refer to the Webtrends Privacy Statement: https://www.webtrends.com/terms-policies/privacy/privacy-statement/.
7 Usage of Matomo
Subject to your consent, we use Matomo (formerly known as PIWIK) to analyse your visit on our website. Matomo is an open-source tool for web analytics. During its use, none of your data will be sent to servers outside our control.
Provided your consent to the analysis via Matomo, the following data will be processed:
(1) 2 bytes of the IP address of the user's calling system.
(2) The accessed web page
(3) The web page from which the user has reached the accessed web page (referrer)
(4) The subpages that are called up from the called-up website
(5) The time spent on the website
(6) The frequency with which the web page is accessed
(7) The Klicks and Actions during the visit
The software solely runs on our servers, which is the sole place of storage for your personal data. That data will not be transferred.
8. Your Rights
Under applicable data protection laws, you have rights
- of access to, rectification of, and/or erasure of your Personal Data;
- to restrict or object to its processing;
- to tell Us that you do not wish to receive marketing information; and
- (in some circumstances) to require certain of your Personal Data to be transferred to you or a third party, which you can exercise by contacting Us at the details set out at the beginning of this Notice.
To the extent our processing of your Personal Data is based on your consent, you also have the right to withdraw your consent, without affecting the lawfulness of our processing based on your consent before its withdrawal.
To exercise your rights, you can contact Us as set out in Section 1.1 above. You can also lodge a complaint about our processing of your Personal Data with a data protection authority.
9. Data Security
LuxCSD and our web operator, ]init[ AG für digitale Kommunikation Köpenicker Str. 9 10997 Berlin, use appropriate technical and organisational security measures in order to protect the data We have under our control against accidental or intentional manipulation, loss, destruction as well as access by unauthorised persons. Our security procedures are continually enhanced as new technology becomes available.