[Date of last modification: 21/09/23]
Privacy Policy
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Privacy Policy
At MyConnectivity G.I.E. (“MyConnectivity” or “we”), we attach great importance to the confidentiality and security of personal data.
MyConnectivity collects and processes data collected on its websites (hereinafter collectively the “Websites“ ), but also data that you transmit to us in the course of your relationship with us, as data controller and in accordance with the provisions of EU Regulation No. 2016/679 of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (the “GDPR“) and any applicable national data protection law (including, but not limited to, the Luxembourg law of 1er August 2018 organising the National Commission for Data Protection and the general system on data protection, as amended from time to time) (collectively the “Data Protection Laws”).
This privacy policy (the “Policy”) describes how we collect, use, and protect the personal data you provide under the conditions described below.
Preamble
1. What Personal Data do we collect?
2. How do we use you Personal Data?
3. Who do we share your Personal Data with?
4. How do we protect your Personal Data?
5. How long is Personal Data kept?
6. What are your rights?
7. Changes to this Policy
1. What Personal Data do we collect?
We collect the following personal data (the “Personal Data“):
● When you visit the Websites: technical information including IP address, device type, browser type, and your email address and any other information you provide when you contact us through our contact form.
● When you engage in a recruitment process with us : your full name, age, gender, date of birth, nationality, citizenship, identity number, passport number, photo ID, images and photographs, address, proof of address, e-mail address, address, telephone number, fax number, job title, professional experience, education, qualifications, hobbies and interests, career plans and communication data exchanged electronically or by other means that predate the employment relationship.
● When you provide us with your business card or after meeting us, you agree to be included in our partner database: your full name, e-mail address, telephone number, job title and employer.
● When you subscribe to our mailing list and become a member of our advisory community (the “Advisory Community”): your full name, telephone number, job title, employer, and other details you choose to share with us.
● When you register to take part in the events we organise: your full name, e-mail address, job title and employer.
You may, at your discretion, refuse to provide us with Personal Data. In this case, however, we may be prevented from fulfilling the above purposes if the Personal Data in question is necessary for this purpose.
When you provide us with Personal Data concerning another natural person, you undertake to process it and to provide it to us in compliance with the Data Protection Laws, including, where applicable, by informing the persons concerned of the content of this Policy, in accordance with articles 12, 13 and/or 14 of the GDPR.
2. How do we use your Personal Data?
We collect Personal Data on the basis of:
● the performance of pre-contractual measures and the establishment of the contractual relationship between us and a job applicant:
when a candidate engages in a recruitment process with us, to register an application, to assess the suitability of the application in relation to the vacancy or existing opportunities, to communicate during selection and recruitment procedures, where appropriate, to contact the candidate with a view to organising one or more interviews and/or scheduling test(s) where appropriate;
● our legitimate interest:
when, after providing us with your business card or after meeting us, you agree to be included in our partner database, for the purposes of managing relations with our customers/partners;
when you join our mailing list and become a member of our Advisory Community, to send you emails relating to our Advisory Community, including newsletters, updates and invitations to events and other opportunities to participate in our community. We may also use your Personal Information to personalise our communications and improve our services;
when you register to take part in our events, in order to monitor participation, prepare the programme, anticipate discussions, and improve the quality of our events.
3. Who do we share your Personal Data with?
We may share your Personal Information with our service providers in charge of our email, the management of the Advisory Community, the management of our contact database, the management of our mailing list, as well as event organisers, in order to facilitate our communications and events. We ensure that these service providers are contractually bound to maintain the confidentiality and security of your information (the “Recipients”).
The Recipients may, under their own responsibility, entrust the processing of said Personal Data to their agents or service providers (the “Sub-Recipients“) who shall process such data solely in order to assist the Recipients in the provision of their service to MyConnectivity and/or to assist the Recipients in complying with their legal obligations.
The Recipients and Sub-Recipients are located in the European Economic Area (“EEA”).
However, in the event that Personal Data is transferred to a third party located in a country outside the EEA which benefits from a European Union adequacy decision, we will do so on the basis of that adequacy decision. Where such third party is located outside the EEA in a country that does not ensure an adequate level of protection for personal data or does not benefit from an adequacy decision of the European Commission, we have entered into legally binding transfer agreements with the relevant third party in the form of standard contractual clauses approved by the European Commission (together with additional measures, if necessary) or any other appropriate safeguards in accordance with the GDPR. In this regard, you have the right to request copies of the relevant document to enable the transfer(s) of personal data to these countries by writing to us at the address below.
4. How do we protect your Personal Data?
We take reasonable steps to protect your Personal Data from unauthorised access, disclosure, or misuse. These measures include implementing technical and organisational security measures to protect against data breaches, as well as regularly reviewing our practices to ensure that we follow best practice.
5. How long do we keep your Personal Data?
We will retain Personal Data for the duration of our relationship with you and for a period of ten (10) years thereafter, unless longer or shorter statutory limitation periods apply. If you have subscribed to our newsletter, we will retain your data until you unsubscribe (via the unsubscribe link in the newsletter).
In certain circumstances, Personal Data may be anonymised so that it can no longer be associated with the individuals concerned, in which case it is no longer Personal Data and may be retained for an unlimited period. Once we no longer need the Personal Data for the purposes for which it was collected, we will securely destroy it in accordance with applicable laws and regulations.
6. What are your rights?
You have the right to access, correct or delete your Personal Data at any time by contacting us at dpo@myconnectivity.lu. You have the right to restrict the processing of your Personal Data, to request the portability of your Personal Data and to object to the collection of your Personal Data. We reserve the right to ask you, in certain cases, to prove your identity. You may also unsubscribe from our mailing list and advisory community at any time by clicking on the unsubscribe link at the bottom of our emails or by contacting us directly.
You also have the right to lodge a complaint with the Commission Nationale pour la Protection des Données (the “CNPD”) at the following address: 15, Boulevard du Jazz, L-4370 Belvaux, Grand Duchy of Luxembourg; or with any competent data protection authority in your Member State of residence, if you consider that your rights set out above have not been respected.
7. Changes to this Policy
We reserve the right to modify or update our Policy at any time. If we make significant changes, we will notify you by e-mail or by posting a notice on the Sites.
In the event of any discrepancy between the French and English versions of this document, the French version shall prevail.