Privacy Policy

The Flexcom S.A.R.L. Privacy Policy (hereinafter “Privacy Policy”) provides information about the collection, use, sharing and processing of personal information by Flexcom S.A.R.L. (hereinafter “Flexcom” or “we”). This Privacy Policy includes your use of our website but also any processing of your personal information (as defined below) when we provide services such as technical support, cloud computing or others.
This Privacy Policy was last updated on 28-01-2021. Nevertheless, it may be amended from time to time, particularly in order to comply with legal requirements or to meet the needs of our evolving business.

This privacy policy complies with the regulations in force applicable to the processing of personal data and, in particular, Regulation (EU) 2016/679 (hereinafter “RGPD”) as well as any Luxembourg regulations arising therefrom.
In this Privacy Policy, the term “personal information” or “personal data” refers to information that relates to an identified or identifiable natural person. For example, this personal information may include, depending on the type of service concerned, your name, e-mail address, business contact information or information collected during your interactions with us via our website.
Flexcom does not process personal data without your consent in connection with the provision of any service, when you use our Web site or when you contact us by any other means. Specific data processing arrangements may be put in place depending on the provision of a particular service or services. In this case, you should also refer to the general terms and conditions of use of these services.

I – Collection and processing of personal data
Certain services offered on our website can only be provided if Flexcom is able to contact you (e.g., requests for products or additional information). In this regard, the ability to use these services is dependent upon your provision of specific personal data (contact information). Flexcom collects, uses and processes this data only to the extent necessary to provide the relevant service to you. Flexcom does not use or process the data in any way except as permitted by law or with your express consent. You may revoke your consent at any time. To do so, please contact the person indicated in Section IX.
The following data will be collected as part of the registration process and will be processed in order to prepare the application: company address, customer status, title, first and last name, telephone and fax number, e-mail address. If you have explicitly consented to this, your e-mail address will also be used to send you a regular newsletter. Flexcom collects personal data on www.flexcom.lu, www.flexcom.ch and www.flexcomlabs.com and/or on the occasion of organized events, in order to optimize our communication with you.
Therefore, Flexcom stores the following information: first name, last name, e-mail address, company name, company address, telephone number, company size, industry, job title, workstation, user behavior based on e-mails sent and user history on www.flexcom.lu.
Flexcom ensures that this information will only be used to create user profiles, will not be shared with third parties and will not be marketed.

We may also process personal information for the following purposes:

  • communicating and responding to your questions and requests for information ;
  • to analyze, develop, improve and optimize the use, function and performance of the website and our products and services ;
  • manage the security of our website, networks and systems;
  • comply with laws and regulations.
    By interacting with our website or using our services, you may also be able to link or connect to websites, services or other features that are not part of our services. As a result of activating these features, third parties other than Flexcom will process your information. Flexcom has no control over the activities of these other parties. We strongly encourage you to review their privacy policies before using such features.

 

II – Use of cookies
To make our site attractive to visitors and to enable the use of certain features, Flexcom uses cookies on different pages. These are small text files stored on your final device. Most of the cookies Flexcom uses are deleted at the end of each browser session (called session cookies).
Other cookies remain on your end device and allow Flexcom to detect your browser the next time you visit (persistent cookies). You can set your browser to notify you when cookies are stored, to allow you to decide whether to accept cookies on a case-by-case basis or to never accept cookies. If you choose not to accept cookies, the functionality of our website may be restricted.
For more information, please refer to our cookie policy.

 

III – Recipient of data
The main recipient of your data is Flexcom.
However, Flexcom may share your personal information with certain subcontractors.
All of our subcontractors are established in the European Union and are committed to comply with the GSPD. Upon written request, Flexcom will provide you with a complete list of its current subcontractors. Flexcom and/or the subcontractors have (have) implemented technical, physical and organizational measures to protect personal information against accidental or unlawful destruction, accidental loss, damage, alteration, unauthorized disclosure or access, and against any other form of unlawful processing.

 

IV- International transfers of personal data
Generally, Flexcom does not transfer personal data internationally. The data is stored on a local and private server.
However, Flexcom or any other third party may transfer, access and store personal data in connection with the provision of services within the European Economic Area if necessary to perform specific services.

 

V – Data Retention
Flexcom will retain your personal data for the purposes for which it was collected, generally for the duration of a contractual relationship or for a maximum period of 10 years except for certain data for which the law requires a retention period of less than 10 years.
When Flexcom processes your personal data following an online application, such data will be deleted as soon as the recruitment process is completed, i.e., as soon as the position is actually filled. However, if Flexcom believes that there is a particular interest (such as a similar position soon to be opened within Flexcom.) in retaining your personal data for a longer period of time not exceeding two years, Flexcom will seek your consent for such retention, with the possibility for unsuccessful candidates to request immediate destruction of their file.

 

VI – Data breach notification and incident management
Flexcom promptly investigates and addresses incidents that suggest or indicate unauthorized access or use of personal information related to specific services.
If Flexcom becomes aware of and determines that an incident involving Service-related Personal Information is a security breach that results in the misappropriation or accidental or unlawful destruction, loss, or alteration, unauthorized disclosure or access to Service-related Personal Information transmitted, stored or otherwise processed on third-party systems made available by Flexcom that compromises the security, confidentiality, or integrity of such Service-related Personal Information, Flexcom will promptly notify you of such breach.
As information relating to the violation is collected or becomes reasonably available to Flexcom, and to the extent permitted by applicable law, Flexcom will provide you with additional relevant information it has about the violation.

 

VII – Rights of Data Subjects

  • The right of access: the data subject has the right to obtain confirmation from the data controller (Flexcom) whether or not personal data concerning him/her are processed and, if so, access to such personal data. Flexcom must be in a position to provide the data subject with full disclosure of his or her personal data.
  • The right of rectification: the data subject has the right to obtain from the data controller (Flexcom), as soon as possible, the rectification of inaccurate personal data concerning him/her.
  • The right of deletion: the data subject has the right to obtain from the data controller (Flexcom) the deletion, as soon as possible, of personal data concerning him/her and Flexcom has the obligation to delete such personal data. In the event of difficulties in exercising these rights, you also have the right to file a complaint with the National Data Protection Commission.
  • The right of limitation of the processing: that is, the right to request the interruption of the processing of your data: when you notice the inaccuracy of a data while waiting for the data controller to verify it; if the processing is unlawful and you prefer a limitation to an erasure; if you need the limitation of the processing for the ascertainment, exercise and defense of your rights in court. In case of limitation, your data may no longer be processed.
  • The right to data portability: the data subject has the right to retrieve the data he has provided in a structured, commonly used and readable format to Flexcom and to pass it on to a third party, if the processing is based on his consent or a contract between him and Flexcom of the data and has been carried out using automated processes.
  • The right to object: you have the right to object at any time to the processing of your data for the future. Your opposition is only valid for the future and not for the past. In the event of an objection, Flexcom will immediately stop the processing of your data. Your objection does not apply, however, if the processing is required by law.
    You have the right to request information at any time about the data Flexcom holds about you, its origin and recipients and the purpose for which it is stored. To do so, please contact the contact person indicated in Section IX. She will investigate and attempt to resolve complaints and disputes arising from the use and disclosure of personal data in accordance with this Privacy Policy and in accordance with applicable laws.
    In the event of difficulties in exercising these rights, you may file a complaint with the National Data Protection Commission (www.cnpd.lu ).

 

VIII – Identity of the data controller and data protection officer
The data controller is Flexcom, represented by Mrs. Merra-Cordella Madison. Her contact details are as follows:
FLEXCOM
Madison MERRA-CORDELLA – Publications Manager
12, Avenue du Rock’n’roll
L-4361 Esch/Belval
Tel: 00352 – 26 15 11 415
rgpd@flexcomlabs.com

 

Flexcom, has appointed a Data Protection Officer whose mission is to ensure compliance with the provisions of the DPMR. This person is Mr. Cellamaro Julien. His contact details are as follows:

FLEXCOM
Mr. Cellamaro Julien
12, Avenue du Rock’n’roll
L-4361 Esch/Belval
Tel: 00352 – 26 15 11 415
dpo@flexcomlabs.com
The data protection officer ensures that the rights of the natural persons whose data are processed by Flexcom are respected.

 

IX – How to contact us
If you wish to report data privacy issues or if you have any questions, comments or complaints, please contact :

  • the Flexcom data controller via the following address: rgpd@flexcomlabs.com.
  • or only our data protection officer via the following address: dpo@flexcomlabs.com.

Flexcom is committed to dealing with complaints about the collection and use of your personal information in a timely manner.
Flexcom reserves the right to correct, modify and update this Privacy Policy at any time. Please check our site regularly to ensure that you are aware of the most current version.