REGULATIONS

Privacy notice

Updated February 18, 2022

To ensure that you are informed about the processing of your data and that your rights to data protection are respected, we have drawn up a privacy policy that complies with the relevant European legislation.

Our privacy principles

As your privacy is important to us, we will only process your data following the following principles:
We will use your personal data in a fair and trustworthy manner.
You have the right to be informed about how we will use your personal data. We will always be transparent with you about what data we collect and how we use it.
If you have any concerns about how we use your personal data, we will assist you in understanding our processing.
We will take all reasonable steps to protect your information from misuse and to keep it secure.
We comply with all applicable data protection regulations and cooperate with the Luxembourg Data Protection Authority (CNPD).

Collection and use of your data

Personal data is data that can be used to directly or indirectly identify or contact a person.
When you browse our website www.lesmoulins.lu or contact us via a form (contact form, registration form for an event organized by Les Moulins de Kleinbettingen S.A. or form for responding to a job offer) or e-mail, we collect your personal information in order to provide you with the requested services or respond to your requests. Unless the information is necessary to fulfill a contract between you and us or a legal obligation, you remain free to provide us with the personal information we request and we undertake to collect only the minimum required to process your request or provide you with the requested service.

If you no longer wish us to retain your data, you may withdraw your consent at any time without inconvenience by contacting the data controller at gdpr@vertico.lu, who takes care of your data.
As the controller of the processing operations for which your information is collected, we are responsible for enforcing your privacy rights and, as such, we take care of your data.
To facilitate the management of your questions and requests, we have designated dedicated persons to take responsibility for this protection of your data. For any information concerning your personal data or questions about how we handle this data, you can contact them by e-mail at gdpr@vertico.lu.

What personal information do we collect?

When you browse our website, we collect your electronic identification data, your behavior, your historical searches and your choices in order to offer you a better experience on our website, especially the next time you visit.
When you contact us via e-mail or an online form, we collect your first and last name, e-mail address, telephone number and any other information you may wish to share with us.
When you apply via our site's online form, by e-mail or by post, we collect your surname, first name, e-mail and postal addresses, as well as any information and documents you may wish to send us to process your application. We use the Skeeled platform to manage applications. This company is GDPR compliance: https://www.skeeled.com/fr/politique-de-confidentialite.
When you subscribe to our newsletter, the data collected is that which you provide to us (when registering for our newsletter). The subcontractor involved in the distribution of our newsletters (Campaign monitor: https://www.campaignmonitor.com/trust/privacy-hub/ ) is subject to the same legal obligations concerning the protection of personal data. Access to your personal data is strictly limited to the minimum required to provide our services.

How we use your personal data?

The personal data we collect enables us to provide you with useful information, dedicated services, quotations, manage your complaints and provide you with any other information you may require. With your explicit consent, we may also send you newsletters about our company, its activities and events, or provide you with commercial offers.

Disclosure to third parties

Your personal data will not be disclosed to third parties, unless you have expressly given your consent, or we are obliged to disclose it, for example, due to a court order or legal obligation.
In the event of a sale, merger or dissolution of our company, we may share your information with the new legal entity, provided that the purposes for which the information is to be processed remain the same, and in any event you will be informed of this in good time.

Transfer outside the European Union

We do not transfer any of your personal information to a country that is not subject to the European Commission's standard contractual clauses. We use subcontractors who undertake to ensure that processing activities are covered by a European Commission decision on privacy issues, in particular in the following cases:
Server logs
In computing, the term "log" (short for "logging") is used to designate a file used to store a history of events attached to a process. The log is a kind of "logbook" for a system.
The server on which our site is hosted contains logs. These logs collect the full IP addresses of our users. They are stored :
Why are they stored? Solely for bug-fixing and performance purposes. Logs are useful, for example, in trying to identify the origin of a breakdown or the author of an intrusion (successful or failed).
Where? On the same server as our site. Our site is hosted by Plateform Sh and their servers are located in Europe. Plateform Sh will adhere strictly to the RGPD on May 25, 2018. Find their protection policy: https://docs.platform.sh/security/gdpr.html
For how long? For a limited time, Plateform SH stores data for up to 14 months.

Protecting your data

We take reasonable steps to protect your personal information at all times. Where necessary, our online services protect your personal information in transit using an encryption protocol such as Transport Layer Security (TLS). Where your personal data is stored, we use restricted-access computer systems housed in facilities employing physical security measures. Where necessary, data will be stored in encrypted form, including when we use third-party storage.

Our organization works with other companies, such as e-mail and SMS providers, automatic information distribution services, Cloud to implement our services, specialized IT services. The selection of a third party follows a comprehensive selection process. In this selection process, each service provider is carefully selected on the basis of its technical and organizational data protection skills. A contract for the processing of personal data will only be concluded if it complies with the security requirements identified, including the requirements of European and national regulations.

Integrity and retention of personal data

We make it easy for you to keep your personal information accurate, complete and up-to-date. We do not keep it longer than is necessary to provide you with the services you have requested, unless we have to keep it for legitimate legal reasons.
To protect such data from accidental or malicious destruction, when we remove it from our services, we may not immediately delete the remaining copies from our servers or backup systems. Complete deletion of data will therefore occur after a full backup cycle.

Our commitment to your privacy

Access to your personal data is restricted to prevent unauthorized access, modification or misuse, and is authorized only for our employees or partners who need it for their work and under a confidentiality agreement.

Specific use of your data

Cookies and related technologies

Our website uses technologies such as "cookies" and other web tools to help us improve your experience and our services. These technologies allow us to better understand user behavior and tell us which pages of our websites are most visited or which features are most appreciated by our users. If these technologies are optional, we will ask for your consent to implement them. Even if some of these technologies are necessary to ensure communication or to provide you with our main services and as such do not explicitly require your consent, we will inform you of their use.
Most browsers are configured to accept cookies automatically. In general, you can prevent cookies from being stored on your hard disk by selecting "Do not accept cookies" in your browser settings. You can also configure your browser to ask for authorization before storing cookies. Finally, you can delete previously set cookies at any time. However, if you set your privacy settings as such, you may not be able to use the full functionality of our website.

Google Analytics

Our website uses Google Analytics. ("Google") and enables us to improve our Internet presence. The information collected by means of a cookie (IP address, access time, access duration) is transmitted to Google servers in the USA and stored there. The evaluation of their activities on our website is transmitted to us in the form of reports, which can also be consulted on a protected site. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. However, to avoid Google having any direct personal relationship with you, we use the "anonymous" function. This means that IP addresses are only processed in abbreviated form and cannot be used to locate you or to create an individual profile by cross-referencing. By using our website, you consent to the processing of data about you by Google in the manner described above.
Certain browser extensions allow you to deactivate and control Google Analytics tracking.

Marketing and advertising

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. These offers contain references to new web offers and information in line with current processing purposes.
If you no longer wish to receive information or newsletters from us by e-mail, you can object at any time by contacting us or by using the link you will find in each of our e-mails or newsletters.

Your privacy rights and questions :
You have the right to:

•  Receive a structured copy of your personal data that we process
• Ask us to correct, update or delete your personal data from our files
• Notify us of any misuse of your personal data
• Withdraw all or part of your consent to the processing of personal data

For all these procedures, simply send us an e-mail to gdpr@vertico.lu clearly specifying the nature of your request so that we can respond as quickly as possible. 

Questions about your rights 

If you have any questions or concerns about our privacy notice or data processing, or if you believe that your personal data has not been processed in accordance with the law, please contact us at gdpr@vertico.lu. Where your question is of a more substantial nature, we may need to contact you to gather further information in order to better respond to your request. If you are not satisfied with the response you receive, you have the right to contact the national data protection authority, i.e. if you are a resident of the Grand Duchy of Luxembourg the CNPD (www.cnpd.lu or databreach@cnpd.lu) or if you are a resident of France the CNIL (www.cnil.fr) and lodge a complaint with them.
We may amend this privacy notice by posting an updated version of these rules on our website. If necessary, we will publish a dedicated notice on our site in the event of a material change.