Privacy policy

ELTRONA INTERDIFFUSION, established and headquartered at 4-8, rue de l’Aciérie, L-1112 Luxembourg, hereinafter referred to as “the Company”, processes personal data (hereinafter referred to as “PD”) relating to natural persons in the course of its commercial activities. In its capacity as Data Controller, the Company undertakes to comply with the rules governing the protection of PD, which are factors contributing to transparency and trust with regard to the persons concerned.

This general policy on the protection of personal data is intended to describe how personal data is used and protected by the Company depending on the type of relationship concerned.

Scope of application

The Company’s DCP Protection Policy sets out the principles and guidelines for its obligations as “Data Controller” ” (the person who determines the purposes and means of processing personal data) arising from 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, which came into force on 25 May 2018 (hereinafter “the Regulation”).

Data collected

The data collected is limited to that necessary for the purposes identified by the Company.

They are collected in particular:

  • when entering into and during the course of a business relationship (e.g. contacts with our sales staff, updates to your customer data, participation in surveys, etc.);
  • when you use our websites;
  • when you submit an application to the Company for a job;
  • with third parties (e.g. municipal authorities);

Different categories of personal data are collected in accordance with legal provisions:

  • personal identification data (e.g. name, date and place of birth, address, telephone number, email address, etc.);
  • bank identification details (e.g. bank account number);
  • data related to online behaviour and preferences when browsing our websites. Further information is available in our cookie policy on page 6 of this document;
  • video recordings inside and around our buildings;
  • recordings of certain telephone conversations;
  • records of electronic communications;
  • data used to assess a candidate's suitability for a position (e.g. qualifications, professional experience, training).

The personal data you provide concerning third parties (landlords, tenants, etc.) is processed in the same way as your personal data, depending on the services and purposes involved. It is your responsibility to inform the persons concerned.

Conditions for the lawfulness of personal data processing

All processing of personal data carried out by the Company is based on one of the following legal grounds:

  • legal and regulatory obligations, e.g. in relation to trading and regulatory reporting to authorities;
  • the performance of a contract, including pre-contractual measures, e.g. the execution and registration of your subscriptions;
  • the legitimate interests of the Company, e.g. commercial activities with customers, such as prospecting, advertising, customer event management;

Profiling and automated individual decision-making

The Company may use profiling, i.e. any form of automated processing of personal data consisting of using such personal data to evaluate certain personal aspects relating to a natural person, in particular to research or identify relatively homogeneous categories of persons likely to be interested in a new product. In this context, your personal data may be processed in the legitimate interest of the Company:

  • for commercial purposes, with the aim of providing services best suited to your needs, including the promotion of products and services complementary to those already subscribed to, marketing activities (newsletters, invitations to events, participation in games, etc.);
  • for the purposes of categorising subscriptions, sending personalised commercial proposals and recommendations
  • to decisions based exclusively on automated processing, using an algorithm to quickly offer you tailored services. The tool then evaluates these responses to determine the subscriptions best suited to your profile.

Right to object to certain processing (Opt-Out)

You have the option to object to certain processing operations described above:

  • Opt-out regarding the categorisation of subscriptions;
  • Opt-out regarding all communications and commercial activities (mailings, invitations to conferences, competitions, etc.).

This right to object may be exercised by post at the following address:

Eltrona Interdiffusion Limited

OPT-OUT

Mr Marcel Kirtz

4-8, Steelworks Street

L-112 Luxembourg

or by email to: [email protected]

by indicating OPT-OUT in the subject line of the email

Consent

Insofar as certain processing of personal data is based on your consent, it will only be carried out after your explicit consent has been obtained. Consent given may be withdrawn at any time, in accordance with the same procedures as those provided for opting out.

Transfer of your data to third parties

The Company transfers PDs to third parties (e.g. external service providers, public authorities) in the course of its activities, when legal, regulatory or contractual provisions authorise or require it to do so. These third parties are also required to comply with legal or contractual obligations regarding the protection of personal data as Data Controllers or Data Processors.

Transfer of your data outside the European Economic Area

Your personal data will only be transferred by the Company outside the European Economic Area (“EEA”) if required to do so by law or regulation. In accordance with the Regulation, the Company will ensure that, for the countries outside the EEA in question, an adequacy decision has been issued by the European Commission or that appropriate safeguards have been put in place.

How long we keep your data

The Company retains your personal data in accordance with its legal obligations or for the period necessary to fulfil the purposes for which it was collected.

Security of your data

The Company undertakes to protect and secure your DCP in order to ensure its confidentiality and prevent its destruction, loss, alteration or disclosure.

To this end, the Company has implemented physical, technical, organisational and procedural protective measures:

  • the Company's staff are made aware of the protection of personal data through internal training, regular memos, the dissemination of best practices, etc.;
  • the Company guarantees that all necessary measures for the protection of personal data are integrated from the outset ("Privacy by Design"), whether in new technological or commercial applications, or in existing applications for which features are added, replaced or modified;
  • The Company guarantees the highest possible level of protection for the personal data it processes ("Privacy by Default"). By default, only data that is likely to be used should be collected and stored. This rule extends to the quantity of personal data, the extent of processing, the length of time data is stored and the accessibility of data. Special categories of personal data (sensitive data) are subject to enhanced security measures.
  • With regard to the subcontracting of DCP processing, the Company contractually requires its subcontractors to provide the same guarantees of DCP security.
  • The Company's Security Policy guarantees a level of protection for PDPs that complies with the Regulation.

All these measures are reviewed regularly and updated.

Notification

In the event of a breach of personal data, the Company, as provided for in the GDPR, shall notify the National Data Protection Commission (CNPD) as soon as possible and, if possible, no later than 72 hours after becoming aware of it. If this breach concerns your personal data and if the incident is likely to result in a high risk to your rights and freedoms, the Company will inform you as soon as possible.

Video surveillance and telephone recordings

The Company reserves the right to use video surveillance inside and around our buildings (shops, car parks, offices, etc.) to ensure your safety and that of its staff, as well as to protect property and facilities.

Unless otherwise specified, video recordings are kept for a period of 30 days to serve as evidence of a crime or damage, or for the purpose of identifying a person (witness, victim, etc.).

For control and certification purposes, the Company is required to record telephone conversations relating to commercial communications. It is understood that these recordings remain covered by professional secrecy and may not be used for any purpose other than those indicated above.

Specific use of your data

Cookies

Cookies are small text files that can be stored on a website visitor’s computer by their web browser. They enable personalised settings to be created on the website. ELTRONA uses cookies to analyse the use of our website in an anonymous or pseudonymised form and to offer users advanced features. Use of the website is not possible without cookies. Most browsers are configured to automatically accept cookies. In general, you can prevent cookies from being stored on your hard drive by selecting “Do not accept cookies” in your browser settings. You can also configure your browser to ask for permission before storing cookies. Finally, you can delete previously set cookies at any time. Please refer to your browser’s instructions for instructions on how to implement this measure.

Use of Google Analytics

Our website uses Google Analytics. This service analyses visits to websites owned by Google Inc. (“Google”) and enables us to improve our online presence. The information collected by means of a cookie (IP address, access time, access duration) is transmitted to Google’s servers in the United States and stored there. The evaluation of their activities on our website is transmitted to us in the form of reports. Google may transmit the information collected to third parties if required by law or if third parties process this data on Google’s behalf.

However, the Google tracking codes on our website use the “anonymised” function, meaning that IP addresses are only processed in abbreviated form in order to exclude any direct personal connection to you. You can also prevent the installation of Google Analytics cookies by configuring your browser software accordingly. In this case, however, you may not be able to use all the features of our website. Certain browser extensions exist that allow you to disable and control Google Analytics tracking.

By using our website, you consent to the processing of data about you by Google.

Use of your data for information and advertising purposes

In addition to providing our services, we also use your personal data to communicate with you about our marketing offers or promotions and to recommend other services that may be of interest to you. In particular, these offers contain references to new telematic and audiovisual offers in line with the current processing purposes.

More specifically, we may use your personal data to send you:

  • information by e-mail about our service offerings if you have created a user account and have explicitly opted in;
  • a newsletter if you have explicitly chosen to receive it on our website or in one of our information emails by clicking on a link indicating that you wish to receive our newsletter.

If you no longer wish to receive information or newsletters from us by e-mail, you may opt out at any time by contacting us or by using the link provided in each of our e-mails or newsletters.

Your rights

The Regulation grants you a series of rights over your PD processed by the Company:

  • the right to access your personal data and, where applicable, to obtain a copy of this data;
  • the right to request the correction or updating of your personal data if you believe it to be incomplete or incorrect;
  • the right to have your personal data deleted, unless there is a legitimate reason for retaining it;
  • the right to object at any time to the processing of your personal data with an opt-out option, unless a legitimate reason prevails over your interests and your rights and freedoms;
  • right to request the restriction of the processing of your personal data;
  • right to the portability of certain personal data, i.e. to receive it in a commonly used, machine-readable structured format in order to transmit it to another data controller.

If you wish to exercise any of the above rights, you may send your request by post to the following address:

Eltrona Interdiffusion Limited

Mr Marcel Kirtz – PRIVACY

4-8, Steelworks Street

L-112 Luxembourg

or by email to [email protected]

by indicating PRIVACY in the title

For confidentiality and data protection purposes, the Company must verify your identity before responding to your request. Therefore, all requests must be accompanied by a photocopy or scan of an identity document.

The Company will endeavour to respond to your request as soon as possible and within one month of receiving the request. Depending on the complexity of the request or the number of requests to be processed, the Company may extend this period by two months. You will be informed of this extension and the reasons for the delay within one month of receiving the request.

The Company reserves the right to refuse the request if it is unable to identify you with certainty or if it considers the request to be excessive or unfounded. You will be informed of the reasons for the refusal within one month of receipt of the request. The Company may also require payment of reasonable fees in the event of unfounded or excessive requests, particularly if they are repetitive in nature.

If you are not satisfied with the response to your request, you may lodge a complaint with the National Commission for Data Protection (information available at www.cnpd.public.lu).

If you are dissatisfied with the handling of your personal data, you may send a complaint by post to the following address:

Eltrona Interdiffusion Limited

Customer Service – DCP

4-8, Steelworks Street

L-112 Luxembourg

or by email to [email protected]

by indicating DCP in the title

Contact

If you have any questions regarding the protection of personal data, you may contact the data controller by post at the following address:

Eltrona Interdiffusion Limited

Mr Marcel Kirtz – INFO-DCP

4-8, Steelworks Street

L-112 Luxembourg

or by email to [email protected]

by indicating INFO-DCP

Policy review

This policy is reviewed once a year and also when practices or regulations require it. Each new version will be submitted to the Company’s Data Protection Committee for approval prior to publication.