Privacy policy

Update - 13/05/2022

We are pleased about your visit to our website. Data protection has a high priority for us. When you use individual functions, services or offers on our website, personal data may be processed.
In order to guarantee clear information about the processing of your personal data and the respect of your rights in terms of data protection, we have implemented a privacy policy in accordance with European law in this area.

An overview of data protection

We want you to feel safe while visiting our website. Therefore, we treat your personal data confidentially and in accordance with the legal data protection regulations and this privacy policy.

Personal data is any data with which you can be personally identified. We only collect, process and use personal data if you have consented to the collection, processing and use or if there is a corresponding legal basis. We reserve the right to change the privacy policy at any time with effect for the future. The current version of the privacy policy can be accessed, saved and printed at any time on our website.

Data recording on this website

Who is the responsible party for the recording of data on this website (i.e., the “controller”)?

The responsible party for data processing on this website is:
Datathings S.A.
5, rue de l'industrie,
L-1811, LUXEMBOURG
LUXEMBOURG

Managing directors: Gregory Nain, Assaad Moawad, Thomas Hartmann and François Fouquet
Phone: (+352) 20 60 03 15
E-mail: contact@datathings.com

The controller is the natural person or legal entity that single-handedly or jointly with others makes decisions as to the purposes of and resources for the processing of personal data (e.g., names, e-mail addresses, etc.).

We have also appointed a data protection officer for our company:
Data Protection Officer Anne-Laure MAZZA 5, rue de l'industrie,
L-1811, LUXEMBOURG
LUXEMBOURG
E-mail: dpo@datathings.com

How do we record your data?

We collect your data as a result of you sharing your data with us. This may, for instance be information you enter into our contact form. Other data shall be recorded by our IT systems automatically or after you consent to its recording during your website visit. This data comprises primarily technical information (e.g., web browser, operating system, or time the site was accessed). This information is recorded automatically when you access this website.

Storage period

Unless a more specific storage period has been specified within this data protection declaration, your personal data will remain with us until the purpose for data processing no longer applies. If you assert a legitimate request for deletion or revoke your consent to data processing, your data will be deleted unless we have other legally permissible reasons for storing your personal data (e.g. retention periods under tax or commercial law); in the latter case, the data will be deleted once these reasons no longer apply.

What purposes do we use your data for?

Some data may be used to analyze your user patterns.

What rights do you have as far as your information is concerned?

You have the right to receive information about the source, recipients, and purposes of your archived personal data at any time without having to pay a fee for such disclosures. You also have the right to demand for your data to be rectified or deleted. If you have consented to data processing, you have the option to revoke this consent at any time, which shall affect all future data processing. Moreover, you have the right to demand that the processing of your data be restricted under certain circumstances. Furthermore, you have the right to log a complaint with the responsible supervising agency. Please do not hesitate to contact us at any time if you have questions about this or any other data protection-related issues. You can find out more about your rights in chapter 2 “Data subject rights

Analysis tools and tools provided by third parties

We work with third-party tools to which personal data is transferred. This forwarding only takes place with your declaration of consent.

Through some of our tools, the so-called analysis tools, your user behavior on the website and our social media channels can be statistically evaluated. This is mainly done with so-called analysis programs. Detailed information on these analysis programs can be found further down in this privacy policy.

Information on data transfer to the USA or other non-EU countries

Among other things, we use tools of companies domiciled in the United States or other non-EU countries, which may be considered non-secure from a data protection perspective. If these tools are active, your personal data may potentially be transferred to these non-EU countries and may be processed there. We must point out that in these countries, a data protection level that is comparable to that in the EU cannot be guaranteed. For instance, U.S. enterprises are under a mandate to release personal data to the security agencies and you, as the data subject, do not have any litigation options to defend yourself in court. Hence, it cannot be ruled out that U.S. governmental agencies may process, analyze, and permanently archive your personal data for surveillance purposes. We have no control over these processing activities.

SSL or TLS encryption

You can recognize an encrypted connection by checking whether the address line of the browser switches from “http://” to “https://” and also by the appearance of the lock icon in the browser line. If the SSL or TLS encryption is activated, data you transmit to us cannot be read by third parties.

Data subject rights

Revocation of your consent to the processing of data

Many data processing operations are only possible with your express consent. You can revoke consent you have already given at any time. The legality of the data processing carried out until the revocation remains unaffected by the revocation.

Right to object to data collection in special cases and to direct marketing (Art. 21 DSGVO)

In the event that data are processed on the basis of art. 6(1)(e) or (f) gdpr, you have the right to object to the processing of your personal data at any time based on grounds arising from your unique situation. This also applies to any profiling based on these provisions. To determine the legal basis, on which any processing of data is based, please consult this data protection declaration. If you log an objection, we will no longer process your affected personal data, unless we are in a position to present compelling protection worthy grounds for the processing of your data,that outweigh your interests, rights and freedoms or if the purpose of the processing is the claiming, exercising or defense of legal entitlements (objection pursuant to art. 21(1) gdpr). If your personal data is being processed in order to engage in direct advertising,you have the right to object to the processing of your affected personal data forthe purposes of such advertising at any time.

Right to report a complaint with the responsible supervisory agency

In the event of violations of the GDPR, data subjects are entitled to log a complaint with a supervisory agency, in particular in the member state where they usually maintain their domicile, place of work or at the place where the alleged violation occurred. The right to log a complaint is in effect regardless of any other administrative or court proceedings available as legal recourses.

Right to data portability

You have the right to demand that we hand over any data we automatically process on the basis of your consent, be handed over to you or a third party in a commonly used, machine-readable format. If you should demand the direct transfer of the data to another controller, this will be done only if it is technically feasible.

Information about the rectification and deletion of data

Within the scope of the applicable statutory provisions, you have the right to at any time demand information about your archived personal data, their source and recipients as well as the purpose of the processing of your data. You may also have a right to have your data rectified or eradicated. If you have questions about this subject matter or any other questions about personal data, please do not hesitate to contact us at any time at dpo@datathings.com

Right to demand processing restrictions

You have the right to demand the imposition of restrictions as far as the processing of your personal data is concerned. To do so, you may contact us (dpo@datathings.com ) at any time. The right to demand restriction of processing applies in the following cases:

  • In the event that you should dispute the correctness of your data archived by us, we will usually need some time to verify this claim. During the time that this investigation is ongoing, you have the right to demand that we restrict the processing of your personal data.
  • If the processing of your personal data was/is conducted unlawfully, you have the option to demand the restriction of the processing of your data in lieu of demanding the deletion of this data. If we no longer require your personal data, and you need it to exercise, defend or claim legal entitlements; you are entitled to demand the restriction of the processing of your personal data instead of its deletion.
  • If you have raised an objection pursuant to Art. 21(1) GDPR, your rights and our rights will have to be weighed against each other. As long as it has not been determined whose interests prevail, you have the right to demand a restriction of the processing of your personal data.
  • If you have restricted the processing of your personal data, this data, with the exception of their archiving, may be processed only subject to your consent or to claim, exercise or defend legal entitlements or to protect the rights of other natural persons or legal entities or for important public interest reasons cited by the European Union or a member state of the EU.

Recording of data on this website

Hosting

Personal data collected on this website are stored on our servers . These may include, but are not limited to, IP addresses, contact requests, metadata and communications, contract information, contact information, names, web page access, and other data generated through a web site.

Our servers will only process your data to the extent necessary to fulfil its performance obligations and to follow our instructions with respect to such data.

Our server is in France

Cookies

Our websites and pages use a tool referred to as “cookies”. Cookies are small text files that do not cause any damage to your device. They are either stored temporarily for the duration of a session (session cookies) or they are permanently archived on your device (permanent cookies). Session cookies are automatically deleted once you terminate your visit. Permanent cookies remain archived on your device until you actively delete them, or they are automatically eradicated by your web browser.

Cookies have a variety of functions. Many cookies are technically essential since certain website functions would not work in the absence of the cookies (e.g., the shopping cart function or the display of videos). The purpose of other cookies may be the analysis of user patterns or the display of promotional messages.

Cookies, which are required for the performance of electronic communication transactions (required cookies) or those that are necessary for the optimization of the website (e.g., cookies that provide measurable insights into the web audience), shall be stored on the basis of Art. 6(1)(f) GDPR, unless a different legal basis is cited. The operator of the website has a legitimate interest in the storage of cookies to ensure the technically error free and optimized provision of the operator’s services. If your consent to the storage of the cookies has been requested, the respective cookies are stored exclusively on the basis of the consent obtained (Art. 6(1)(a) GDPR); this consent may be revoked at any time.

You have the option to set up your browser in such a manner that you will be notified any time cookies are placed and to permit the acceptance of cookies only in specific cases. You may also exclude the acceptance of cookies in certain cases or in general or activate the delete function for the automatic deletion of cookies when the browser closes. If cookies are deactivated, the functions of this website may be limited. This prevents the setting of cookies and thus you can permanently object to the setting of cookies. In addition, you can delete cookies that have already been set at any time via your browser. The transmission of Flash cookies cannot be prevented via the settings of your browser, but by changing the setting of the Flash Player. This also applies to all third-party cookies listed below.

In the event that third-party cookies are used or if cookies are used for analytical purposes, we will separately notify you in conjunction with this Privacy Policy and, if applicable, ask for your consent.

Cookie consent

Whenever you visit our website, cookies will be stored in your browser, which archives any declarations or revocations of consent you have entered. The recorded data shall remain archived until you ask us to eradicate them, or the purpose of storing the data no longer exists. This shall be without prejudice to any retention obligations mandated by law.

Server log files

The provider of this website and its pages automatically collects and stores information in server log files, which your browser communicates to us automatically. The information comprises:

  • The type and version of browser used
  • The used operating system
  • Referrer URL
  • The hostname of the accessing computer
  • The time of the server inquiry
  • The IP address

This data is not merged with other data sources.

This data is recorded on the basis of Art. 6(1)(f) GDPR. The operator of the website has a legitimate interest in the technically error free depiction and the optimization of the operator’s website. In order to achieve this, server log files must be recorded. This data is evaluated exclusively to ensure the permanent and trouble-free operation of the website and to improve the content of our website as well as for transmission to law enforcement authorities in the event of a cyber-attack and to ensure the security of our information technology systems. An evaluation of your data for marketing purposes does not take place in this context.

Contact form

If you submit inquiries to us via our contact form, the information provided in the contact form as well as any contact information provided therein will be stored by us in order to handle your

Inquiry and in the event that we have further questions. We will not share this information without your consent.

The information you have entered into the contact form shall remain with us until you ask us to eradicate the data, revoke your consent to the archiving of data or if the purpose for which the information is being archived no longer exists (e.g., after we have concluded our response to your inquiry). Mandatory legal requirements – in particular retention periods – remain unaffected.

Request by e-mail, telephone, or fax

If you contact us by e-mail, telephone or fax; your request, including all resulting personal data (name, request) will be stored and processed by us for the purpose of processing your request. We do not pass these data on without your consent.

This data is processed on the basis of Art. 6(1)(b) GDPR, the data is processed on the basis of our legitimate interest in the effective handling of inquiries submitted to us (Art.6(1)(f) GDPR) or on the basis of your consent (Art. 6(1)(a) GDPR) if it has been obtained.

The data sent by you to us via contact requests remain with us until you request us to delete, revoke your consent to the storage or the purpose for the data storage lapses (e.g. after completion of your request). Mandatory statutory provisions, in particular statutory retention periods, remain unaffected.

Analysis tools and advertising

Google Tag Manager

We use the Google Tag Manager. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The Google Tag Manager is a tool that allows us to integrate tracking or statistical tools and other technologies on our website. The Google Tag Manager itself does not create any user profiles, does not store cookies, and does not carry out any independent analyses. It only manages and runs the tools integrated via it. However, the Google Tag Manager does collect your IP address, which may also be transferred to Google’s parent company in the United States.

The Google Tag Manager is used on the basis of Art. 6(1)(f) GDPR. The website operator has a legitimate interest in the quick and uncomplicated integration and administration of various tools on his website. If the relevant consent has been requested, the processing is carried out exclusively on the basis of Art. 6(1)(a)GDPR; the consent can be revoked at any time.

Google Analytics

This website uses functions of the web analysis service Google Analytics. The provider of this service is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland. Google Analytics enables the website operator to analyze the behavior patterns of website visitors. To that end, the website operator receives a variety of user data, such as pages accessed, time spent on the page, the utilized operating system and the user’s origin. Google may consolidate these data in a profile that is allocated to the respective user or the user’s device.

Furthermore, Google Analytics allows us to record your mouse and scroll movements and clicks, among other things. Google Analytics uses various modeling approaches to augment the collected data sets and uses machine learning technologies in data analysis.

Google Analytics uses technologies that make the recognition of the user for the purpose of analyzing the user behavior patterns (e.g., cookies or device fingerprinting). The website use information recorded by Google is, as a rule, transferred to a Google server in the United States, where it is stored.

This analysis tool is used on the basis of Art. 6(1)(f) GDPR. The operator of this website has a legitimate interest in the analysis of user patterns to optimize both, the services offered online and the operator’s advertising activities. If a corresponding agreement has been requested (e.g., an agreement to the storage of cookies), the processing takes place exclusively on the basis of Art. 6(1)(a) GDPR; the agreement can be revoked at any time.

You can prevent the collection of data generated by the cookie and related to your use of our website (including your IP address) to Google and the processing of this data by Google by downloading and installing the browser add-on available at this link http://tools.google.com/dlpage/gaoptout?hl=en. The installation of the browser add-on is considered by Google as an objection. The terms of use and privacy policy of Google and Google Analytics can be found here https://policies.google.com/privacy?hl=en&gl=en and here: https://marketingplatform.google.com/about/analytics/terms/gb/ , respectively.

Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here:https://privacy.google.com/businesses/controllerterms/mccs

IP anonymization

On this website, we have activated the IP anonymization function. As a result, your IP address will be abbreviated by Google within the member states of the European Union or in other states that have ratified the Convention on the European Economic Area prior to its transmission to the United States. The full IP address will be transmitted to one of Google’s servers in the United States and abbreviated there only in exceptional cases. On behalf of the operator of this website, Google shall use this information to analyze your use of this website, to generate reports on website activities and to render other services to the operator of this website that are related to the use of the website and the Internet. The IP address transmitted in conjunction with Google Analytics from your browser shall not be merged with other data in Google’s possession.

Browser plug-in

You can prevent the recording and processing of your data by Google by downloading and installing the browser plugin available under the following link: https://tools.google.com/dlpage/gaoptout.

For more information about the handling of user data by Google Analytics, please consult Google’s Data Privacy Declaration at: https://support.google.com/analytics/answer/6004245.

Archiving period

Data on the user or incident level stored by Google linked to cookies, user IDs or advertising IDs (e.g. DoubleClick cookies, Android advertising ID) will be anonymized or deleted after 2 months. For details, please click the following link: https://support.google.com/analytics/answer/7667196

Mails in general & first contact via e-mail

If you would like to write to us, or you contact us in writing, we are obliged in the case of initial contact in accordance with Art. 12, 13 GDPR to provide you with the following important data protection information: If you contact us by e-mail, we will process your personal data only,

  • insofar as there is a legitimate interest in the processing (Art. 6 para. 1 lit. f GDPR),
  • you have consented to the data processing (Art. 6 para. 1 lit. a GDPR),
  • the processing is necessary for the initiation, establishment, content or amendment of a legal relationship between you and us (Art. 6 para. 2 lit. b GDPR)
  • or another legal basis permits the processing.

Your personal data will remain with us,

  • until you request us to delete it,
  • you revoke your consent to storage,
  • or the purpose for which the data was stored ceases to apply (e. g. after the processing of your request has been completed) you revoke your consent to storage,

Legal requirements – in particular tax & commercial law conservation periods – remain unaffected. Of course, you have the right to obtain information about the origin, recipient and purpose of your stored data at any time. You also have the right of objection, data portability and the right to complain to the responsible supervisory authority. Furthermore, you may request the authorization, deletion and, under certain circumstances, the restriction of the processing of your personal data. For details, please refer to section 3 “General information and mandatory data protectioninformation”aboveinourprivacypolicy.

Plug-ins and tools

YouTube with expanded data protection integration

Our website embeds videos of the website YouTube. The website operator is Google Ireland Limited(“Google”), Gordon House, Barrow Street, Dublin 4, Ireland. We use YouTube in the expanded data protection mode. According to YouTube, this mode ensures that YouTube does not store any information about visitors to this website before they watch the video. Nevertheless, this does not necessarily mean that the sharing of data with YouTube partners can be ruled out as a result of the expanded data protection mode. For instance, regardless of whether you are watching a video, YouTube will always establish a connection with the Google DoubleClick network.

As soon as you start to play a YouTube video on this website, a connection to YouTube’s servers will be established. As a result, the YouTube server will be notified, which of our pages you have visited. If you are logged into your YouTube account while you visit our site, you enable YouTube to directly allocate your browsing patterns to your personal profile. You have the option to prevent this by logging out of your YouTube account.

If you are logged in with your personal Google account while visiting our website, YouTube can associate your visit and the specific subpages of our website that you visit with your account. If you do not have a Google account, it is still possible that YouTube stores your IP address. Insofar as you do not wish such processing, you must log out of your Google account and delete your cookies before visiting our website. You can object to the use of your data by Google at any time by clicking on the following link: https://adssettings.google.com/authenticated/.

Furthermore, after you have started to play a video, YouTube will be able to place various cookies on your device or comparable technologies for recognition (e.g. device fingerprinting). In this way YouTube will be able to obtain information about this website’s visitors. Among other things, this information will be used to generate video statistics with the aim of improving the user friendliness of the site and to prevent attempts to commit fraud.

Under certain circumstances, additional data processing transactions may be triggered after you have started to play a YouTube video, which are beyond our control.

The use of YouTube is based on our interest in presenting our online content in an appealing manner.Pursuant to Art. 6(1)(f) GDPR, this is a legitimate interest. If a corresponding agreement has been requested, the processing takes place exclusively on the basis of Art. 6(1)(a) GDPR; the agreement can be revoked at any time.

For more information on how YouTube handles user data, please consult the YouTube Data Privacy Policy under: https://policies.google.com/privacy?hl=en

Google Maps

This website uses the mapping service Google Maps. The provider is Google Ireland Limited (“Google”),Gordon House, Barrow Street, Dublin 4, Ireland.

To enable the use of the Google Maps features, your IP address must be stored. As a rule, this information is transferred to one of Google’s servers in the United States, where it is archived. The operator of this website has no control over the data transfer. In case Google Maps has been activated, Google has the option to use Google web fonts for the purpose of the uniform depiction of fonts. When you access Google Maps, your browser will load the required web fonts into your browser cache, to correctly display text and fonts.

We use Google Maps to present our online content in an appealing manner and to make the locations disclosed on our website easy to find. This constitutes a legitimate interest as defined in Art. 6(1)(f) GDPR. If a respective declaration of consent has been obtained, the data shall be processed exclusively on the basis of Art. 6(1)(a) GDPR. This declaration of consent may be revoked at any time. Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the EuropeanCommission. Details can be found
here: https://privacy.google.com/businesses/gdprcontrollerterms/
and https://privacy.google.com/businesses/gdprcontrollerterms/sccs/.

For more information on the handling of user data, please review Google’s Data Privacy Declaration under:
https://policies.google.com/privacy?hl=en.

eCommerce and payment service providers

Processing of data (customer and contract data)

We collect, process, and use personal data only to the extent necessary for the establishment, content organization or change of the legal relationship (data inventory). These actions are taken on the basis of Art.6(1)(b) GDPR, which permits the processing of data for the fulfillment of a contract or pre-contractual actions. We collect, process, and use personal data concerning the use of this website (usage data) only to the extent that this is necessary to make it possible for users to utilize the services and to bill for them. The collected customer data are stored per 10 years in accordance with the Article 16 of Code de commerce of Luxembourg and with Article 5 of GDPR. This shall be without prejudice to any statutory retention mandates.

Custom Services

Job applications

We offer website visitors the opportunity to submit job applications to us (e.g., via e-mail, via postal services or by submitting the online job application form). Below, we will brief you on the scope, purpose and use of the personal data collected from you in conjunction with the application process. We assure you that the collection, processing and use of your data will occur in compliance with the applicable data privacy rights and all other statutory provisions and that your data will always be treated as strictly confidential.

Scope and purpose of the collection of data

If you submit a job application to us, we will process any affiliated personal data (e.g., contact and communications data, application documents, notes taken during job interviews, etc.), if they are required to make a decision concerning the establishment or an employment relationship. The legal grounds for the aforementioned are (Negotiation of an EmploymentRelationship), Art. 6(1)(b) GDPR (General Contract Negotiations) and – provided you have given us your consent – Art. 6(1)(a) GDPR. You may revoke any consent given at any time. Within our company, your personal data will only be shared with individuals who are involved in the processing of your job application.

If your job application should result in your recruitment, the data you have submitted will be archived on the grounds of Art. 6(1)(b) GDPR for the purpose of implementing the employment relationship in our data processing system.

Data Archiving Period

If we are unable to make you a job offer or you reject a job offer or withdraw your application, we reserve the right to retain the data you have submitted on the basis of our legitimate interests (Art. 6(1)(f) GDPR) for up to 24 month from the end of the application procedure (rejection or withdrawal of the application). Afterwards the data will be deleted, and the physical application documents will be destroyed. The storage serves in particular as evidence in the event of a legal dispute. If it is evident that the data will be required after the expiration of the 24 months period (e.g., due to an impending or pending legal dispute), deletion will only take place when the purpose for further storage no longer applies.

Longer storage may also take place if you have given your agreement (Article 6(1)(a) GDPR) or if statutory data retention requirements preclude the deletion.