Privacy statement for customers & service providers of LuxConnect S.A.
Last Updated: 14 May 2025
Last Updated: 14 May 2025
1. General information
Privacy statement for customers & service providers of LuxConnect S.A.
Our commitment
LuxConnect is committed to protecting your privacy and ensuring the protection of your personal information. This privacy statement explains the type of personal data (hereafter called PII, personal identifiable information) we collect and how we use, disclose and protect it.
What does this statement cover?
These rules of conduct on privacy apply to all PII that you have transmitted during an approach to an employee of LuxConnect and that can be processed during commercial activities.
Who is responsible for your data?
The company LuxConnect is responsible for your PII and ensures compliance with the regulations. You can contact LuxConnect or its Chief Executive Officer under: info@luxconnect.lu, +352 27 61 68 1.
LuxConnect also acts as a processor, e.g., for hosting health data or other sensitive data, in which case the customer is responsible for your data.
Additionally, LuxConnect has appointed a data protection officer to assist you in executing your rights.
Contact DPO
itrust consulting s.à r.l. dpo@luxconnect.lu
How to change these rules?
We may change this privacy statement by posting an updated version on our website. For every major change, we will post a notice in the Home page on our website in the news section.
2. Our Privacy Principle
LuxConnect takes privacy seriously. In accordance with the privacy policy implemented within our company, the following five principles are at the basis of our service approach to respect your privacy:
a. we always use your PII in a fair, trustworthy and transparent way for specified, explicit and legitimate purposes;
b. you have the right to be clearly informed about how we use your PII. We will always be transparent to you about the data we collect and the way we use it;
c. if you have concerns about how we use your PII, we assist you in understanding our treatments;
d. we will take all reasonable steps to protect your information from abuse and to keep it safe;
e. we are committed to all European and national privacy regulations and shall cooperate with your national supervisory authority (in Luxembourg the CNPD) regarding privacy where necessary.
3. Rules of conduct at LuxConnect
What is the mission of LuxConnect?
LuxConnect is committed to protecting your privacy and is committed to safeguarding your personal information. These privacy guidelines explain the type of personal data we collect and how we use, disclose and protect it.
What are the purposes of the treatments?
LuxConnect will keep data concerning contractual relationships, 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 collection and processing of your PII is limited to the following purposes:
- To grant access to customer after identification; to manage access based on a badge; to report access granted to customers;
- To manage and execute customer (B2B) order and contractual obligation; to manage presales activities;
- To invoice customer and follow-up payments;
- To manage staff actions, including documentation in the information systems;
- To ensure the security of IT system by logging and monitoring activities;
- To manage and organise work efficiently; to ensure workplace safety;
- To manage salary and social security;
- To ensure physical security, to detect alerts in case in movements, to identify intruders.
Who is concerned by data processing?
The following are concerned:
- all customers, in particular customer’s staff interacting with LuxConnect;
- all contractual partners and subcontractors;
- all candidates for recruitment at LuxConnect.
How is your PII collected?
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.
We may collect PII from a variety of sources, including:
a. information you give us directly;
b. information that we may collect via our browsing activities on our websites luxconnect.lu and we may collect on sources like LinkedIn, twitter, etc.
c. Internet, partners under NDA, and other people based on consent (related to candidate assessment).
What PII does LuxConnect have at its disposal?
In these privacy rules, your PII means one or more set(s) of information that could identify you directly or indirectly. This generally includes information such as your name, address, date and place of birth, social security number, identifiers, profile image, email address, telephone number, electronic information (IP address, browsing information), 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) and any information collected via our cameras, it may also include other information about your past or current business activities and also information including PII which you may transmit to us and candidate evaluations.
How long is the data retained?
Your personal data is kept for the time necessary to achieve the above-mentioned purposes.
These periods may, however, be increased by the need to apply statutory limitation periods. The retention periods have been defined in the record of processing activities and can be consulted on the premises of LuxConnect.
Depending on the purpose or provisions of the archiving laws, the retention period could be extended. Indeed, some images are kept and used for historical purposes.
In anonymised form, your personal data may be used for statistical purposes beyond the above-mentioned retention period.
Knowledge management for the provision of business services and management of customer data in record or processing is as below:
Type of Data
Identity pictures, access authorization.
Privately owned SME not paying bills.
Login (time) and activity reports.
Illness reports.
Identity pictures, access authorization for video monitoring.
Retention time
10y
10 years (accounting)
10 y
10y after end of contract
90 days
Deletion time after request
1 month
3 months
3 months
3 months
1 month
With whom is your PII shared?
As a general rule, we do not share your PII outside LuxConnect. However, as part of the management of your personnel file and that of remuneration and social security contributions, we communicate your data to carefully selected and controlled subcontractor Brink’s Security Luxembourg S.A. in B.P. 1652, L-1016 Luxembourg (managing the ‘Accessing the building’ for LxC while securing the building).
We may also share your PII with organizations if we believe that disclosure of the information is necessary for legal reasons in the context of lawsuits.
Are your PII transferred to third countries (outside the EU and partner countries)?
We do not transfer any of your personal information to servers outside the European economic area (EEA) or to a country not subject to the EU Commission’s standard contractual clauses. We use subcontractors who undertake to keep your data on EEA territory or we ensure that processing activities are covered by a European Commission adequacy decision regarding the privacy issues, in particular in the case described hereafter. For further information about our subcontractors you may contact our DPO.
How do we protect your PII?
We take reasonable security measures to protect your personal information at any times and require any third party who handles or processes your PII for us to do so.
If LuxConnect collaborates with other companies, the choice of these companies will only be made after a complete selection process. In this selection process, each individual service provider is carefully selected for its relevance in terms of technical and organizational data protection expertise. This selection process will be documented and a contract for the processing of contractual data will only be concluded if the service provider complies with the identified security requirements, including European and national regulatory requirements.
Access to your PII is restricted to prevent from unauthorized access, modification or misuse, and is only permitted to our employees who need it for their work.
Specific processing of your data
Cookies
Our websites use technologies such as ‘cookies’ or other web tools to help us improve your experience and our services. These technologies help us to better understand user behaviour, tell us which parts of our website users have visited, and facilitate and measure the effectiveness of your experience. Although some of these technologies are necessary for communication purposes or to provide you with our core services and as such do not explicitly require your consent, we will inform you of their use.
Most browsers are set to automatically accept cookies. In general, you can prevent the storage of cookies on your hard disk by selecting ‘Do not accept cookies’ in your browser settings. You can also configure your browser to ask permission before storing cookies. Finally, you can delete previously set cookies at any time. Please refer to the instructions of your browser on how to implement this measure. If you set your privacy setting as such, however, it may happen that you cannot fully use all the features of our website.
Marketing and advertising
In addition to providing our services, and on explicit opt in for newsletters by the user, we will use your PII to communicate with you about our offers or marketing promotions and to recommend other services that may interest you. In particular, these offers may contain references to new service offers in line with the present processing purposes.
If you no longer want to receive these recommendations or newsletters from us, you can object to this at any time by disabling this in your settings, contacting us or by using the link that you find in each of our communications.
Which roles are assumed by LuxConnect when customers hosts Health data in our infrastructure ?
Business name of the actor
LuxConnect S.A.
Role in the hosting service (1)
Host
HDS certified (yes / no / exempted)
Yes
SecNumCloud 3.2 qualified
No
Hosting activities in which the player is involved
Provision of energy, cooling, colocation access management and dark fibre installation services
Outside access (2)
No, no access to data from a country outside the European Economic Area
Related risk (3)
No
(1) Host / processor of the Host
(2) Access to personal health data from countries outside the European Economic Area, by the Host or one of its processors (Requirement No. 29 of the HDS framework)
(3) Host or processor subject to a risk of access to personal health data from countries outside the European Economic Area, imposed by the legislation of a third country in breach of EU law (Requirement No. 30 of the HDS framework)
What are your rights and how can you exercise them?
The legal rules on the protection of PII, in particular the rights of the data subjects concerned by the processing operations carried out are applicable under the relevant conditions and subject to the exceptions and derogations provided for.
For questions relating to the processing of your data or in order to exercise your rights, you may contact the Data Protection Officer of LuxConnect,
· by sending an email to the following address: dpo@luxconnect.lu
· or by registered mail to
LuxConnect S.A.Data Protection Officer
202, Z.A.E. Wolser F
L-3290 Bettembourg, Luxembourg,
While enclosing with your application a legible and valid copy of your identity document and, if applicable, that of the person for whom you are the legal representative.
If you have any questions, comments or concerns about how we handle your PII, you can contact the data controller, the chief executive officer or the data protection officer directly.
You have the right to:
a. ask us for a copy of your PII we process;
b. ask us to correct, update, or delete your PII from our records;
c. report to us any misuse of your PII.
d. be duly informed about the use and processing of your personal data in conformity to the GDPR;
e. receive all the personal data ,in particular situations specified in the GDPR, 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;
f. access the security camera footage on which you appear.
In the event of a request for deletion of your data, LuxConnect will check that there are no other purposes or rights of another data subject that would oblige it to keep them. In this case, the decision should be notified.
If you request a copy of your file, LuxConnect will analyse it in order to delete any information on other persons.
If you feel that your PII has not been processed in accordance with the law, you should contact our DPO for clarification.
90 days