Privacy Policy

LuxConnect S.A. Luxembourg
Last Updated: 27 December 2019

In the light of the entry into force of the Regulation (EU) 2016/679 of 27 April 2016 (General Data Protection Regulation, hereinafter referred to as the “GDPR”) on 25 May 2018 and with regard to the provisions of the applicable legislation (together hereinafter referred to as the“Data Protection Law”), LuxConnect S.A. wishes to outline its personal data processing.
LuxConnect S.A. is established and has its registered office at L-3235 BETTEMBOURG, 4, rue Alexander Graham Bell, and is registered with the Luxembourg Trade and Companies Register under the number B 120379. It is hereinafter referred to as “LuxConnect”.
In conformity to the GDPR, LuxConnect is a data controller.

The legal basis

The legal basis for the processing of your personal data, on the one hand, is the proper execution of your contract as concluded with LuxConnect. On the other hand, it is the processing necessary for the purposes of the legitimate interests pursued by LuxConnect or by a third party. For certain processing, more than one legal basis may be applicable (such as for camera surveillance as further described below).
A final legal basis for the processing of your personal data for specific purposes may be your consent, which you may withdraw at any moment. If the processing is done in parallel on another legal basis, the withdrawal of your consent will not in principle impact the processing by LuxConnect (or at least not the full extent of the processing).

Personal data

Name

• Address
• Date and place of birth
• Social security number
• Photo and/or any other reproduction
• Any information which can be collected by way of an ID-Badge (including under certain circumstances information regarding access to and exits from our premises)
• Any information collected via our cameras

Collection of personal data

Personal data will be collected when you first enter into contact with LuxConnect, when you fill out any forms or communicate with us, for instance by phone or e-mail. Furthermore, personal data will be gathered whenever you use your ID-Badge or pass through an area where surveillance cameras have been installed. The purposes of these cameras are to guarantee the proper execution of the contracts concluded with our clients and the safety of any visitor on our premises, and to control the safety of the material located on our premises (protection against theft, destruction etc.). At the same time, these purposes constitute the legitimate interests that justify the video surveillance.
More specifically, cameras have been installed in the following areas: DC1 and DC2 premises and the common areas of the building.
Of course, LuxConnect guarantees that security camera footage is kept secure by applying the appropriate technical and/or organisational measures.

More specifically, cameras have been installed in the following areas: DC1 and DC2 premises and common area of the building.

LuxConnect guarantees of course that the security camera footage is kept secure by using appropriate technical and/or organizational measures.

Purpose and processing / use of personal data

LuxConnect collects your personal data in order to be able to deliver the performances as defined in your contract.

For this reason, LuxConnect will keep data concerning your contractual relationship, among other things, in electronic form, and such data may only be stored for professional use, transferred to any other place of work of LuxConnect or the group of which LuxConnect is a member, including companies of the group that are established abroad, or to subcontractors or other co-contractors of LuxConnect (e.g. for the execution of a mission with said co-contractor etc.)
Your personal data are kept no longer than is necessary for the purposes for which they are collected and processed.
The retention period essentially depends on the type of data. As an example, data relevant to the accounting of the company may be kept for a duration of up to 10 years after the end of the contractual relationship.
As for the footage collected from the surveillance cameras, the data will automatically be deleted after the maximum period authorised by local regulations, i.e. 30 days.
As for the log files collected from the access control system, the data will automatically be deleted after the maximum period authorised by local regulations, i.e. 90 days.

Who will be in contact with my personal data?

Depending on the data concerned, the persons occupying the following positions are the recipients of your personal data:

• Datacenter Manager and Deputy Datacenter Manager
• Manager Operations Security & Risk Assessment
• Security Team
• Sales and Marketing Team
• Company Management

Rights

In respect of your personal data, you have the following rights:

• the right to be duly informed about the use and processing of your personal data in conformity to the GDPR;
• the right to access your personal data in conformity to the GDPR;
• the right to rectify your personal data, to request erasure of your personal data, provided that constraints and legal obligations applicable to LuxConnect do not conflict with such a request;
• in particular situations specified in the GDPR, the right to obtain the restriction of processing so that the personal data may only be processed with your consent (without prejudice to our right to store the data in accordance with data protection law). The enforcement of this right does not impact any previous processing;
• in particular situations specified in the GDPR, the right to receive all the personal data which concern you and and have been provided by you to LuxConnect, and to transfer these data to another controller (right to data portability). LuxConnect reserves the right to charge a fee for such transfer, especially in case of frequent requests and/or in the event of a request deemed excessive in terms of the volume of data to be transferred. You must inform LuxConnect in writing in due time before the end of the contract if you intend to make use of this right. Otherwise, LuxConnect cannot be held responsible for the erasure of the personal data;
• without prejudice to any other administrative or legal remedy, the right to lodge a complaint with the national supervisory authority (Commission Nationale pour la Protection des Données – CNPD) if you consider yourself to be the victim of a breach in the processing of your personal data;
• and, with respect to video surveillance, the right to access the security camera footage on which you appear.

In respect of your personal clients and other third parties:

If LuxConnect is processing personal data about your clients or about any other third party (hereinafter referred to as “Third Parties”), and those data have not been directly received by LuxConnect from such Third Parties, LuxConnect – in addition to the information contained in this Privacy Notice – indicates that:

• the following categories of personal data relating to such Third Parties may be processed:
  • Name
  • Address
  • Date and place of birth
  • Social security number
  • Photo and/or any other reproduction
• any information which can be collected by way of an ID-Badge (including under certain circumstances information regarding access to and exits from our premises)
• any information collected via cameras
• as for the source where the personal data originate, LuxConnect may receive such personal data from you as our direct client who has a link with such Third Parties and possibly from also publicly accessible sources
• at LuxConnect no automated decisions are made regarding the personalised data of Third Parties
• third Parties have the same rights in relation to the processing of their personal data as those summarised above in the section entitled “Rights”.

Contact details:

Any questions or requests relating to personal data should be addressed to info@luxconnect.lu