(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 25^th 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).

Personal data

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

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

Security Team

Sales and Marketing Team

Company Management

Rights

In regard to 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, the right to require erasure of your personal data, provided that constraints and legal obligations applicable to LuxConnect do not conflict with such a request;
• the right to obtain in particular situations specified in the GDPR, 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 execution of this right does not impact and previous processings;
• the right to receive in particular situations specified in the GDPR, all personal data which concerns you and provided by you to LuxConnect and to transfer this 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 volume of data to be transferred. You have to inform LuxConnect in writing in due course 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;
• the right without prejudice to any other administrative or legal remedy to lodge a complaint with the national supervisory authority (Commission Nationale pour la Protection des Données – CNPD) if you consider yourself being 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.

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:

• 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 of you
• all information which can be collected by way of an ID-Badge (including under certain circumstances information regarding access to and exits from our premises)
• all information collected via our cameras
• as for the source where the personal data originates, LuxConnect may receive such personal data from you as our direct client who has a link with such Third Parties and possibly from publicly accessible sources
• at LuxConnect no automated decision making with the personalised data of Third Parties happens
• third Parties have the same rights in relation with the processing of their personal data as those summarized here above under section “Rights”.

Contact details:

Any questions and demands relating to personal data should be addressed at info@luxconnect.lu