1. Who is responsible for your personal data

 This Privacy Notice explains how LUXHUB SA (“LUXHUB”, “we”, “us” or ”our”) collects, uses, shares and otherwise processes your Personal Data in connection with your relationship with us as a client, Third-Party Provider (TPP), acting for a client or TPP, or being generally interested in our services, in accordance with applicable data privacy laws and the General Data Protection Regulation 2016/679 (“GDPR”) which is applicable as of 25 May 2018.

We control the ways your Personal Data are collected and the purposes for which we use your Personal Data acting as “data controller” for the purposes of the GDPR.

 

2. Personal data we collect about you

When using the term “Personal Data” in our Privacy Notice, we mean information that relates to you and allows us to identify you, either directly or in combination with other information that we may hold. Your personal data may include for example your name, your contact details or information on how you interact with us.

We will process your Personal Data if and to the extent applicable law provides a lawful basis for us to do so. We will therefore process your Personal Data only:

  1. if you have consented to us doing so
  2. if we need it to perform the contract we have entered into with you, or
  3. if we need it to comply with a legal obligation, or
  4. if we (or a third party) have a legitimate interest which is not overridden by your interests or fundamental rights and freedoms. Such legitimate interests will be the provision of services by us, administrative or operational processes and direct marketing.

 

Categories of data we collect

Data category

Type

Personal identification data

·         Name and surname

·         Title

·         Postal and/or e-mail address

·         Phone numbers

·         Date of birth

·         Salutation (Mr / Mrs / Ms)

Professional information

·         Job title

·         Department and name of organization

·         Professional postal and/or e-mail address

·         Professional phone numbers

  

Sensitive personal data

In the course of providing services to you, we may collect information that could reveal your racial or ethnic origin or conviction of criminal offences. Such information is considered “sensitive personal data” under the GDPR. We only collect this information in the case you have given your explicit consent, it is necessary according to legal obligations, or you have deliberately made it public.

By providing any sensitive personal data you explicitly agree that we may collect and use it in order to provide our services and in accordance with this Privacy Notice.

If you do not allow us to process any sensitive personal data, this may lead to us being unable to provide all or parts of the services that you have requested from us.

 

3. How and why we use your Personal Data

We use your Personal Data for the following purposes:

  • To provide our services to you
  • To communicate with you and manage our relationship with you
  • To personalize and improve your user experience
  • To improve our services, fulfil our administrative purposes and protect our business interests
  • To comply with our legal obligations

We will only use your Personal Data for the purposes for which we collected it and which we informed you about, unless we reasonably consider that we need to use it for another reason which is compatible with the original purpose. If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

 

4. Your rights in relation to your Personal Data

Under the GDPR you have rights as an individual which you can exercise under certain circumstances in relation to your Personal Data that we hold. These rights are to:

  • request access to your Personal Data (commonly known as a “data subject access request”) and request certain information in relation to its processing;
  • request rectification of your Personal Data;
  • request the erasure of your Personal Data;
  • request the restriction of processing of your Personal Data;
  • object to the processing of your Personal Data.

If you want to exercise one of these rights please contact us at This email address is being protected from spambots. You need JavaScript enabled to view it.

You also have the right to lodge a complaint at any time with the National Commission for Data Protection (“CNPD”), the Luxembourg supervisory authority for data protection issues, or, as the case may be, any other competent supervisory authority of an EU member state.

 

5. Security of your Personal Data

We are committed to taking appropriate technical and organisational measures to protect your Personal Data against unauthorised or unlawful processing and against accidental loss, destruction or damage.

All your Personal Data in electronic format will be stored within the European Union. Any Personal Data in physical form will be kept in a secure location at our premises in Luxembourg.

 

6. Retention period

We will only retain your Personal Data for as long as we need it in order to fulfil the purposes for which it was collected and processed, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements.

In some circumstances we may anonymise your Personal Data so that it can no longer be associated with you, in which case it is no longer considered as Personal Data. Upon expiry of the applicable retention period we will securely destroy your Personal Data in accordance with applicable laws and regulations.

 

7. Sharing your Personal Data

Please note that we may use or disclose Personal Data if we are required by law to do so or if we reasonably believe that use or disclosure is necessary to protect our rights and/or to comply with judicial or regulatory proceedings, a court order or other legal process.

 

8. Cookies

 When you visit this website, cookies may be automatically installed and temporarily saved in your computer in order to make it easier for you to navigate around our site. Cookies do not enable us to identify you, but are used to record information about the pages you have viewed on our website, the date and time of your visit to the site, etc.

To manage your cookies you can visit the help page of your web browser:

Matomo

This website uses Matomo as web analytics service. The processing of personal data with Matomo is based on legitimate interest of LUXHUB.

Matomo is used to analyse the behaviour of the Developer Portal visitors to identify potential pitfalls; not found pages, search engine indexing issues, which contents are the most appreciated, etc.

 

Personal data processed by Matomo:

Matomo is processing the following personal data:

  • Cookies
  • IP address
  • User ID
  • Custom Dimensions
  • Custom Variables
  • Order ID
  • Location of the user
  • Date and time
  • Title of the page being viewed
  • URL of the page being viewed
  • URL of the page that was viewed prior to the current page
  • Screen resolution
  • Time in local timezone
  • Files that were clicked and downloaded
  • Link clicks to an outside domain
  • Pages generation time
  • Country, region, city
  • Main Language of the browser
  • User Agent of the browser
  • Goals, Campaigns, Events
  • Session recording, mouse events (movements, content forms and clicks)
  • Form interactions
  • Media interactions
  • A/B Tests

 

Legitimate interest

Processing your personal data such as cookies is helping us identify what is working and what is not on our website. For example, it helps us identify if the way we are communicating is engaging or not and how we can organize the structure of the website better. Our team is benefiting from the processing of your personal data, and they are directly acting on the website. By processing your personal data, you can profit from a website which is getting better and better.

Without the data, we would not be able to provide you the service we are currently offering to you. Your data will be used only to improve the user experience on our website and help you find the information you are looking for.

 

Recipient of the personal data

The personal data received through our website are sent to:

 

9. Fees

You will in general not have to pay a fee to exercise any of your individual rights mentioned in this Privacy Notice. However, we may charge a reasonable fee if your request to exercise your individual rights is manifestly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

 

10. Updates to our Privacy Notice

We reserve the right to update this privacy notice at any time, and we will make an updated copy of such privacy notice publicly available.

 

11. Contact information

If you have any concerns or require any further information, please do not hesitate to contact us at This email address is being protected from spambots. You need JavaScript enabled to view it. or send your request to the following address:

 

LUXHUB

Attn. DATA PROTECTION

153-155 rue du Kiem

L-8030 Strassen