(Luxconnect S.A. Luxembourg)
Last Updated: May 23th, 2018
In the light of the entry into force of the Regulation (EU) 2016/679 of 27 April 2016 (General Data Protection Regulation, hereafter “GDPR”) on the 25th May 2018 and in regard to the provisions of the applicable legislation (together hereafter “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, registered with the Luxembourg Trade and Companies Register under number B 120379, hereafter referred to “LuxConnect”.
In conformity to the GDPR LuxConnect is a data controller.
The legal basis
The legal basis for the processing of your personal data is on the one hand the good execution of your contract concluded with LuxConnect and on the other hand the processing is necessary for the purposes of the legitimate interests pursued by LuxConnect or by a third party. For certain processing, more than one legal basis can 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 can be your consent, which you can withdraw at any moment. If the processing is in parallel based on another legal basis, then the withdrawal of you consent will in principle not impact the processing by LuxConnect (or at least not the full extent of the processing).
The collection of personal data
Personal data will be collected when you first enter into contact with LuxConnect, when you fill out any forms or by communicating for instance via phone or email with us. Furthermore, personal data will also be gathered whenever you use your ID-Badge or are passing an area where surveillance cameras have been installed. These cameras have as purposes to guarantee the good execution of the contracts concluded with our clients, the safety of any visitor circulating within our premises, as well as to control the safety of the material located within our premises (protection against theft, destruction etc.). These purposes constitute at the same time the legitimate interests justifying the video surveillance.
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.
The 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.
Therefore, LuxConnect will keep data concerning your contractual relationship, among others, in electronic form, and such data may only be stored for professional use, transferred to any other place of work of LuxConnect or of the group of which LuxConnect is a member, including companies of the group that are established abroad, as well as to subcontractors or other co-contractors of LuxConnect (e.g. for the execution of a mission with this 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 for the accounting of the Company may be kept for 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 concerned data, the persons occupying the following positions are the recipients of your personal data:
Datacenter Manager and Deputy Datacenter Manager
Manager Operations Security & Risk assessment
Sales and Marketing Team
In regard to your personal data, you have the following rights:
With respect to your personal clients and other third parties:
If LuxConnect is processing personal data about your clients or about any other third party (hereafter “Third Parties”), which has not been directly received by LuxConnect from such Third Parties, LuxConnect indicates in addition to the information contained in this Privacy Notice that:
Any questions and demands relating to personal data should be addressed at firstname.lastname@example.org