1. The client is informed that our company treats Personal Data relating to them in strict
compliance with all applicable laws and regulations, industry standards and other applicable
requirements that relate in any way to the privacy, data protection, confidentiality or security
of Personal Data and apply to the delivery of the Subscribed Services, including European
Union directives and regulations governing the protection of Personal Data, and notably the
Regulation EU 2016/679 of the European Parliament and of the Council of 27 April 2016 on
the protection of natural persons with regard to the processing of personal data and on the free
movement of such data, and repealing Directive 95/46/EC, as may be replaced, amended or reenacted (hereinafter “GDPR”).
The Personal Data processed is the information concerning the client that is provided to our
company at the time of the conclusion of the Contract and which is generated through use of
the Subscribed Services and the performance of the Contract.
The communication of the Personal Data necessary for the execution of the contract is obligatory for the client.
2. Personal Data are processed by our Company insofar as this is necessary:
(a) For the performance and execution of the Contract.
(b) To meet the purposes of the legitimate interests pursued by our company or by a third party,
for instance, for billing purposes, customer management, in the fight against fraud, to enforce
these Terms and Conditions.
(c) For the purpose of providing evidence of a commercial transaction or any other commercial
3. The client is informed that, in strict compliance with the provisions of the GDPR, our
company retains and processes the relevant Personal Data after the end of the Contract for a
minimum period of 10 years after the date of the contract.
Our company will comply with applicable legislation and any directives issued by the
authorities in this regard.
4. The client is informed that, in strict compliance with the provisions of the GDPR, all or part
of the Personal Data may be transmitted to the client, to third parties, the local authorities, the
companies which request it with the prior consent of the client, to the public on the Internet and
to the extent permitted by the law, to public organizations, administrative or legal authorities
and supervisory bodies.
Personal Data may therefore be communicated or made accessible to persons outside the
European Union who are not in a country offering an adequate level of protection within the
meaning of the legislation on the protection of Personal Data.
5. The client is informed of their right to:
(a) Access, free of charge at reasonable intervals, the Personal Data held about him and receive
additional information about how it is processed;
(b) Rectify any inaccurate Personal Data or complete any incomplete Personal Data;
(c) Seek the erasure of their Personal Data when the processing of their Personal Data is no
longer necessary for the purposes described in article 2. above, when the client has withdrawn
his consent to a specific processing (to the extent that consent justifies this processing), when
the processing is not or no longer lawful for any reasons, when the erasure is necessary to
comply with applicable law or when the client objects to the processing either in the absence of
any overriding legitimate ground for such processing or when the processing is carried out for
direct marketing purposes;
(d) Object at any time to processing for direct marketing purposes and to object, on grounds
relating to their particular situation, to any processing based on our company’s legitimate
(e) Receive the Personal Data relating to the client and transmit them to another data controller
to the extent that the legitimacy of the processing lies on contractual performance and is carried
out by automated means; and
(f) Seek the restriction of the processing for instance when the client contests the accuracy of
the Personal Data or when the processing is not or no longer compliant with applicable law and
the client has objected to the erasure of the Personal Data;
(g) Withdraw his consent to the processing to the extent that the legitimacy of such processing
lies on consent.
Any changes to Personal Data must be notified promptly by the client to our company.
The client may exercise these rights by emailing our company at email@example.com.
In addition, the client has a right to file a complaint with the Luxembourg data protection
authority, the “Commission nationale pour la protection des données” (CNPD), in case they
have concern about the processing of his Personal Data.
Hereafter, the contact details of the “Commission nationale pour la protection des données”:
Address: 1, avenue du Rock’n’Roll, L-4361 Esch-sur-Alzette
Telephone: (+352) 26 10 60 -1
Fax. : (+352) 26 10 60 – 29