PRIVACY POLICY
Protecting your privacy is an important concern for INDUNA and we care about how your personal information is handled.
As data controller, INDUNA subscribes to the rules on the protection of personal data for the purpose of transparency and trust towards the data subjects.
So INDUNA is committed to describe you:
- What personal data we collect about you
- How we obtain your personal data
- How we use your personal data
- On what basis do we use your personal data
- How long we keep your personal data
- With whom we share your Personal Data
- How we protect your personal data
- To which countries we transfer your personal data
- Your rights concerning your personal data
1. PERSONAL DATA COLLECTED
The personal data collected is limited to those necessary to achieve the purposes identified by INDUNA.
INDUNA may collect personal data about you in connection with its activities, including when you use its website, when you contact or request information, when you hire its services.
The personal data that INDUNA processes may include:
- personal identification data (eg, name, date and place of birth, address, phone number, email address);
- economic and financial data (eg bank account number, income, origin of wealth);
- data on the heritage situation (eg income, credits, wealth);
- professional data (eg CVs, professional status, working time);
- the connection data (eg Ip address, access badge);
- location data (eg GPS data, mobile, camera, fuel card);
- the data needed for the KYC file.
2. OBTAINING PERSONAL DATA
INDUNA has to obtain personal information in different ways:
- When entering into relationship and during it.
- When using the website through email communications sent to INDUNA.
- When submitting an application for a waged job.
3. USE OF PERSONAL DATA
INDUNA collects and processes personal data about you in a number of ways, including through your use of its website and the provision of its services.
INDUNA uses this information to:
- Provide and improve services to you.
- Provide the information requested by you.
- Comply with its legal, regulatory and risk management obligations.
- Recruitment.
4. THE BASIS OF THE USE OF PERSONAL DATA
INDUNA uses your personal data on the following bases:
An agreement to enter into a relationship between a service contract or other contract (eg employment contract). Comply with legal and regulatory obligations, particularly with regard to the fight against money laundering.
5. THE TIME OF CONSERVATION OF PERSONAL DATA
INDUNA keeps your personal data in accordance with its legal obligations or for the time necessary to achieve the purposes for which they were collected. These periods are based on the requirements of applicable data protection laws and the purpose for which they are collected and used, taking into account the legal and regulatory requirements for keeping information for a minimum period, limitation periods, and good practices.
6. THE COMMUNICATION OF PERSONAL DATA TO THIRD PARTIES
INDUNA may share your personal data with certain trusted third parties including:
- Suppliers to whom INDUNA outsources services.
- Third parties engaged in the services that INDUNA provides to customers and with their prior consent, such as banks.
Where necessary, personal information may also be shared with regulators.
In this case INDUNA will do its best to inform you in advance unless INDUNA is legally prevented from doing so.
7. PROTECTION OF PERSONAL DATA
INDUNA uses various technical and organizational measures to protect your personal information from unauthorized access, use, disclosure, modification or destruction, in accordance with applicable data protection laws.
8. COUNTRIES IN WHICH PERSONAL DATA ARE LIKELY TO BE TRANSFERRED
In order to provide its services, INDUNA may be required to transfer your personal data to sites outside the country. This may result in the transfer of your information to a country located in the European Economic Area (the "EEA") outside the EEA, or from outside the EEA to a country within the European Economic Area ("EEA"). EEA.
The level of protection of information in non-EEA countries may be lower than that offered in the EEA. In this case, INDUNA takes appropriate measures to ensure that your personal information remains protected and secure in accordance with applicable data protection laws. Where INDUNA's third party service providers process personal data outside the EEA as part of the provision of services, INDUNA's written agreement with them will include appropriate measures, usually standard contractual terms.
9. YOUR RIGHTS REGARDING YOUR PERSONAL DATA
The EU general data protection regulation provides for certain rights for data subjects:
- right to access your personal data and if necessary to obtain a copy of this data;
- right to request the rectification or updating of your personal data, if you consider that they are incomplete or incorrect;
- right to obtain the erasure of your personal data, unless a legitimate reason justifies their conservation;
- right to oppose at any time the processing of your personal data unless a legitimate reason prevails over your interests and your rights and freedoms;
- right to request the limitation of the processing of your personal data;
- right to the portability of certain personal data, that is to say receive them in a structured format commonly used, readable by machine in order to transmit them to another Processing Manager.
If you wish to exercise one of the rights mentioned above, you can send your request by email or mail to the following address:
INDUNA
Data Protection
51-53, rue de Merl
L-2146 Luxembourg
E-mail: dataprotection@groupinduna.com
Your objection (or the withdrawal of any previously given consent) could mean that INDUNA is unable to perform the actions necessary to achieve the objectives stated above (see "3. Use of Personal Data").
If you wish to make a complaint, or if you feel that INDUNA has not satisfactorily addressed your concern, you may contact the CNPD.
The complaint submission form may be submitted:
Online on the CNPD website:
https://cnpd.public.lu/en/particuliers/faire-valoir/formulaire-plainte.html
By post to the following address:
Commission nationale pour la protection des données
Service des réclamations
15, Boulevard du Jazz
L-4370 Belvaux