Privacy policy

This Privacy Policy satisfies the disclosure requirements according to Art. 12 ff. of the EU General Data Protection Regulation (“GDPR”) and provides a summary of the processing of your personally identifiable information (“personal data”, “personal information”) on this web-site.

Privacy Policy and Cookies Policy

1.      WHO IS ACCOUNTABLE FOR PROCESSING MY PERSONAL DATA?

Majorel Group Luxembourg S.A.
18, boulevard de Kockelscheuer
L-1821 Luxembourg

Email:privacy@majorel.com

is responsible for processing your personal data on this website (hereinafter referred to as “we”).

We process personally identifiable information (“personal data”) in accordance with GDPR provisions.

You can contact our designated Data Protection Officer at the address indicated above by using the reference ‘For the attention of the Data Protection Officer’ or by writing to privacy@majorel.com with the subject line ‘For the attention of the Data Protection Officer’.

2.      WHAT DATA IS COLLECTED?

When you visit our website, the data of the computer you use to access our website is automatically logged (“access data”). This access data includes server log files that generally consist of information pertaining to your web browser type and version, your operating system, your internet service provider (ISP), the date and time you used the website, the websites previously visited by you and the websites you accessed from our website, in addition to the IP address of your computer. With the exception of your IP address, the information contained in the server log files is not personally identifiable. An IP address is personally identifiable when it is static (permanently allocated when using internet access) and the ISP is able to attribute it to a specific person.

Some features of our website require that you divulge personal information to us. In this case, the information provided by you is used to provide the service requested by you or process a matter submitted by you (e.g. search queries, entries made in forms or contracts, click data). Other services on this website will require you to provide information such as your first and last name, email address and phone number. These are required in cases you wish us to contact you back.

3.      WHAT COOKIES ARE USED?

Cookies are used on our website. Cookies are small text files that are saved to your computer when visiting a website. The cookies that are saved can be attributed to the web browser used by you. When the website is visited again, the web browser returns the content of the cookies, thus enabling you, the user, to be recognized. Certain cookies are deleted when you log out or end the browser session (“transient cookies” or “session cookies”). Other cookies are saved for a specific period of time (“temporary cookies”) or indefinitely (“persistent cookies”). These cookies are automatically deleted when the defined period lapses. The privacy and security settings of your browser enable cookies to be deleted at any time and also enable you to configure the use of cookies in accordance with your preferences. However, you may not be able to use all the features of our website if you delete the cookies used by our website.

As a general principle, cookies enable online recognition without reference to a specific person. Cookies may become personally identifiable when the information they contain is merged with other information apart from the information generated by the cookies themselves. Depending on their function and purpose, the cookies we use can be divided into the following categories: Technically necessary cookies, preference cookies, statistics cookies and marketing cookies.

3.1  Technically necessary cookies

These services, technologies and cookies are necessary to help make a website usable by enabling basic functions like page navigation and access to secure areas of the website. They are used on the legal basis of Art. 6 para. 1 lit. f (overriding legitimate interests) of the General Data Protection Regulation (GDPR). The legitimate interests are in particular the monitoring of the technical performance of the website as well as our interest in the economic use of partner sales channels. The website cannot function properly without these cookies. They can therefore not be deactivated via our Consent Management System and by you as a website user. Among others, we use the following technically necessary cookies:

• Cookiebot (CookieConsent [x5]): Enables users to individually control their data transfer. The Consent Management Platform is used to query and document the user’s decision and to transfer it to other systems. Cookiebot offers a software concept that classifies cookies according to their purpose and offers website visitors the possibility to allow or prevent certain cookie classes.
• Youtube (CONSENT [x2]): Used to determine whether the visitor has accepted the marketing category in the cookie banner. This cookie is necessary for the website’s compliance with the GDPR.

3.2  Preference cookies

Preference Cookies enable a website to remember information that changes the way the website behaves or looks, like your preferred language or the region that you are in. They are used on the legal basis of Art. 6 para. 1 lit. a GDPR (your consent). The data processing only begins when you have given the corresponding opt-in. You can withdraw your consent at any time with effect for the future (see privacy settings).  The withdrawal of consent shall not affect the lawfulness of processing based on the consent before its withdrawal.

• Cookiebot (CookieConsentBulkSetting-#): Enables consent to cookie use for multiple websites
• Own website cookies (pll_language [x5]): Used to determine the visitor’s preferred language and to set the language accordingly on the website, if possible.
• Quriobot cookie (qb [x2]): Quriobot cookies are used to store user preferences and settings. They expire when the browser session ends or 1 hour after the chat ends.

3.3  Statistic cookies

These services, technologies and cookies are needed to understand how our visitors use our website, to detect errors and to continuously improve the website.  They are used on the legal basis of Art. 6 para. 1 lit. a GDPR (your consent). The data processing only begins when you have given the corresponding opt-in. You can withdraw your consent at any time with effect for the future (see privacy settings). The withdrawal of consent shall not affect the lawfulness of processing based on the consent before its withdrawal.

3.3.1.     Google Analytics and Google Tag Manager

This website uses Google Analytics, a web analytics service provided by Google, Inc. 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google"). Google Analytics uses “cookies", which are text files placed on your computer, to help the website analyze how users use the site.

Google Tag Manager is a solution that allows marketers to manage website tags through one interface. The Tag Manager tool itself (which implements the tags) is a cookie-less domain and does not collect any personal data. The tool takes care of triggering other tags, which in turn may collect data. Google Tag Manager does not access this data. If a deactivation has been made at the domain or cookie level, it remains in place for all tracking tags implemented with Google Tag Manager. https://marketingplatform.google.com/about/analytics/tag-manager/use-policy/

The following cookies are used on this website:

•  _gid: Registers a unique ID that is used to generate statistical data about how the visitor uses the website.
• collect: Used to send data to Google Analytics about the visitor’s device and behavior. Captures the visitor across devices and marketing channels.
• gat: Used by Google Analytics to limit the request rate.
• _ga: Registers a unique ID that is used to generate statistical data about how the visitor uses the website.

The information generated by the cookies about your use of this website is usually transmitted to a Google server in the USA and stored there.

However, if IP anonymisation is activated on this website, your IP address will be shortened by Google beforehand within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activity and to provide other services related to website activity and internet usage to the website operator.

The IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data. You can prevent the storage of cookies by setting your browser software accordingly; however, we would like to point out that in this case you may not be able to use all the functions of this website to their full extent. You can also prevent Google from collecting the data generated by the cookie and relating to your use of the website (including your IP address) and from processing this data by Google by downloading and installing the browser plug-in available under the following link: tools.google.com/dlpage/gaoptout.

Please note that this data may be transferred outside the European Union and the European Economic Area and to a country that does not offer an adequate level of data protection. If the data is transferred to the USA, there is a risk that your data may be processed by US authorities for control and monitoring purposes without you possibly being entitled to legal remedies.

The legal basis for the processing of your data in this case is your consent in accordance with Art. 6 para. 1 lit. a GDPR. With regard to the transfer of third countries, the processing is carried out in accordance with Art. 49 para. 1 lit. a GDPR.

The data will be deleted as soon as they are no longer needed for the processing purposes, but at the latest after 1 year.

More information on data processing at Google Analytics can be found in Google’s privacy policy: https://policies.google.com/privacy.

3.3.2.     Further cookies used

We use the following additional cookies for our website

• ADRUM_BT1 [x2] / ADRUM_BTa [x2]): These cookies track errors that users may receive and provide our technical teams with insight to make sure that we can improve your user experience.

3.4  Marketing cookies

These services, technologies and cookies are used to track visitors across websites. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third party advertisers. They are used on the legal basis of Art. 6 para. 1 lit. a GDPR (your consent). The data processing only begins when you have given the corresponding opt-in. You can withdraw your consent at any time with effect for the future (see privacy settings).  The withdrawal of consent shall not affect the lawfulness of processing based on the consent before its withdrawal.

3.4.1.     Google AdWords

This website uses AdWords by Google, Inc. 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google") to re-engage visitors that are likely to convert to customers based on the visitor’s online behavior across websites.

We use scripts from Google Adwords to create remarketing lists or similar target groups in order to personalize our online advertising. Google links sessions on our website (first-party cookie) to one of Google’s ad cookies on users’ browsers (third-party cookie). If you later perform a search on google.com using the same browser, you may see customized ads based on your previous sessions on our platform. Google may use the data collected in conjunction with the data they have about you to personalize advertising on their own network. We ourselves do not collect or process any personal data as part of Google AdWords. We only receive statistical evaluations from Google. Based on these evaluations, we can see which of our advertisements in the Google advertising network are particularly effective. We do not receive any further data, and in particular we cannot identify our users on the basis of this information.

If you do not wish to use Google’s remarketing function, you can deactivate it by changing the corresponding settings under http://www.google.com/settings/ads.

For further information regarding the processing by Google please see section 3.3.1.

3.4.2.     Google DoubleClick

This website uses Google DoubleClick by Google, Inc. 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google") to record and report the user’s actions on the website after viewing or clicking on one of the provider’s ads, with the purpose of measuring the effectiveness of an advertisement and displaying targeted advertisements to the user.

Google uses a cookie ID to record which ads are displayed in which browser and can thus prevent them from being displayed more than once. In addition, DoubleClick can use cookie IDs to record so-called conversions that are related to ad requests. This is the case, for example, when a user sees a DoubleClick ad and later calls up the advertiser’s website with the same browser and buys something there. According to Google, DoubleClick cookies do not contain any personal information.

Due to the marketing tools used, your browser automatically establishes a direct connection with Google’s server. We have no influence on the scope and further use of the data collected by Google through the use of this tool and therefore inform you according to our state of knowledge: Through the integration of DoubleClick, Google receives the information that you have called up the relevant part of our website or clicked on the ad from us. If you are registered with a Google service, Google can assign the visit to your account. Even if you are not registered with Google or have not logged in, there is a possibility that the provider learns your IP address and stores it.

You can prevent participation in this tracking process in various ways: a) by setting your browser software accordingly – suppressing third-party cookies will result in you not receiving third-party ads; b) by disabling cookies for conversion tracking by setting your browser to block cookies from the domain www.googleadservices.com (https://www.google.de/settings/ads) whereby this setting will be deleted when you delete your cookies; c) by deactivating the interest-based ads of the providers that are part of the self-regulatory campaign “About Ads" via the link http://www.aboutads.info/choices whereby this setting will be deleted when you delete your cookies; d) by permanently deactivating them in your browsers Firefox, Internet explorer or Google Chrome under the link http://www.google.com/settings/ads/plugin. We would like to point out that in this case you may not be able to use all functions of this offer to their full extent.

For more information on DoubleClick by Google, please visit https://www.google.de/doubleclick and http://support.google.com/adsense/answer/2839090,

For further information regarding the processing by Google please see section 3.3.1.

3.4.3.     YouTube

YouTube is a Google-owned platform for hosting and sharing videos. YouTube collects user data through videos embedded in websites, which is aggregated with profile data from other Google services in order to display targeted advertising to web visitors across a broad range of their own and other websites.

The following cookies are used on this website:

• YouTube (VISITOR_INFO1_LIVE): Tries to estimate user bandwidth on pages with integrated YouTube videos.
• YouTube (YSC, yt.innertube::nextId [x2], yt.innertube::requests [x2]): Registers a unique ID to keep statistics of the videos from YouTube that the user has watched.
• YouTube (YSC, yt.innertube::nextId [x2], yt.innertube::requests [x2]): Registers a unique ID to keep statistics of the videos from YouTube that the user has watched.
• YouTube (yt-remote-cast-available [x2] and other cookies listed in the cookie banner): Saves the user settings when retrieving a Youtube video integrated on other web pages.

For further information regarding the processing by Google please see section 3.3.1.

4.      WHAT PERSONAL DATA IS COLLECTED AND FOR WHAT PURPOSE?

The purpose of data processing may be based on technical, contractual or statutory requirements or result from consent having been given by the user.

We use the data described in section 2 for the following purposes:

• To provide website features and content and ensure technical security in trouble-shooting technical issues and also to ensure that unauthorized persons do not gain access to our website systems;
• To conduct marketing reach measurements and web analyses in order to make our website more efficient and interesting for you, and for market research purposes;
• For communication, completion of precontractual procedures, and customer care purposes;
• To send out newsletters via email;
• For event registration and participation; and
• Founding an employment relationship.

For information on other data processing purposes, please refer to the sections below of this Privacy Policy.

4.1 PROVISION OF THE WEBSITE

4.1.1 DESCRIPTION AND SCOPE OF DATA PROCESSING

In order to enable the proper functioning of our website, security analyses to be conducted, and denial-of-service attacks to be prevented and stopped, server log files are automatically collected and saved on a short-term basis as an integral part of access data that is created by the system of the visiting computer upon accessing our website and while using it (see section 2). The content of the server log files is not merged with other data. We use the server log files for statistical analyses to troubleshoot and remedy technical issues, prevent and defend against denial-of-service attacks and attempted fraud, and to optimize the proper functioning of our website.

4.1.2 PURPOSE AND LEGAL BASIS OF DATA PROCESSING

The legal basis for the creation of server log files follows from Art. 6 para. 1 lit. f GDPR. Our legitimate interests lie in the proper functioning of our website, conducting security analyses and defending against threats.

4.1.3 DURATION OF STORAGE OR CRITERIA APPLIED IN DEFINING THIS PERIOD

When the pages of our website are accessed, information is logged to server log files that are stored on our web server; the IP address contained in them is deleted after 7 days at the latest. No analysis is conducted during this time unless there is a denial of service or other attack.

4.1.4 OPTIONS FOR LODGING AN OBJECTION AND HAVING YOUR DATA REMOVED

You have the right to lodge an objection to the processing of your data contained in the server log files provided that there are cogent reasons that arise from your specific situation. If you would like to exercise your right to lodge an objection, please write to the contact address in section 1.

4.2 CONTACT FORM, EMAIL, CHATBOT AND TELEPHONE CONTACT INFORMATION

4.2.1 DESCRIPTION AND SCOPE OF DATA PROCESSING

On our website you have the option of contacting us by way of a contact form, by email, by telephone or by chatbot using the designated email address and phone number. If you take advantage of this option, the information you enter in the contact form, your email address and/or your phone number are disclosed to us and stored in a dedicated database. Depending on the reason you are contacting us (questions about our products and services, pursuing your rights as a data subject, e.g. submitting a request for information) your contact details are processed (with the assistance of service providers). If necessary for processing your request, this information may be shared with third parties (e.g. partner companies).

4.2.2 PURPOSE AND LEGAL BASIS OF DATA PROCESSING

The legal basis for processing your contact details follows from Art. 6 para. 1 lit. f  GDPR. We have legitimate interests in processing your request and in continued communication. If the purpose for your establishing contact with us is to enter into a contract with our company, the legal basis for processing your contact details follows from Art. 6 para. 1 lit. b GDPR.

4.2.3 DURATION OF STORAGE OR CRITERIA APPLIED IN DEFINING THIS PERIOD

Your contact details are deleted once your request has been processed and further communication has been discontinued. This does apply if the purpose of your establishing contact with us is to conclude a contract or you wish to exercise your right as a data subject (e.g. request information). In this case your details are stored until all contractual and/or statutory obligations have been fulfilled and statutory retention periods (currently 6 to 10 years) do not prevent this information from being deleted.

4.2.4 OPTIONS FOR LODGING AN OBJECTION AND HAVING YOUR DATA REMOVED

You have the right to lodge an objection to the processing of your contact information provided that there are cogent reasons that arise from your specific situation. If you would like to exercise your right to lodge an objection, please write to the contact address in section 1. If you lodge an objection, communication with you cannot be continued. This does not apply if the storage of your contact details is necessary for completing precontractual procedures, fulfilling a contract or exercising your rights as a data subject.

4.3 ASSERTING YOUR RIGHTS AS A DATA SUBJECT

4.3.1 DESCRIPTION AND SCOPE OF DATA PROCESSING

On the website you have the possibility of asserting your rights as a data subject, e.g. request information on your personal information that is currently stored by us in relation to your visit of the website. In order to assert your rights as a data subject, it may be necessary that you provide us information pertaining to your person and the specific information that has been processed. Without providing this information, we are not able to cater to your rights as a data subject.

4.3.2 PURPOSE AND LEGAL BASIS OF DATA PROCESSING

The legal basis for processing your personal information in asserting your rights as a data subject follows from Art. 6 para. 1 lit. c GDPR, “Complying with a legal obligation”.

4.3.3 DURATION OF STORAGE OR CRITERIA APPLIED IN DEFINING THIS PERIOD

We store the correspondence exchanged with you in relation to your asserting your rights as a data subject for a period of three years. This does not apply to information obtained to clarify your identity, e.g. by way of a labeled photocopy of your personal identity card, where we have been provided one. It will be deleted within one week at the latest of establishing your identity.

4.3.4 OPTIONS FOR LODGING AN OBJECTION AND HAVING YOUR INFORMATION REMOVED

The processing of your information is required for complying with your rights as a data subject, and to that extent you have no right to revoke your consent to its processing.

4.4 STUDIES, REPORTS AND WHITEPAPERS

4.4.1 DESCRIPTION AND SCOPE OF DATA PROCESSING

The website offers free studies, reports and whitepapers from Majorel Group Luxembourg S.A. Data is requested and processed further for sending the files with the assistance of service providers. When registering, your consent is obtained and you are advised of this Privacy Policy. Your details are not shared with third parties not involved in the direct provision of the content. The obligatory information required for receiving Majorel Group Luxembourg S.A. free studies, reports and whitepapers is your email address. Processing your access data is also necessary to show proof of your giving your consent. Other information may be voluntarily provided in order to address you personally.

4.4.2 PURPOSE AND LEGAL BASIS OF DATA PROCESSING

Processing the information entered by you in the registration form is necessary for advertising pertaining to products and/or services provided by us. The legal basis for this is your consent pursuant to Art. 6 para. 1 lit. a GDPR.

4.4.3 DURATION OF STORAGE OR CRITERIA APPLIED IN DEFINING THIS PERIOD

Your information is stored to show proof that we obtained your consent for sending you Majorel’s free studies, reports and whitepapers. The same applies if you have revoked your consent.

4.4.4 OPTIONS FOR LODGING AN OBJECTION AND HAVING YOUR DATA REMOVED

You can revoke your consent to receiving press releases at any time by writing to Majorel Group Luxembourg S.A. (18, boulevard de Kockelscheuer , L-1821 Luxembourg, Email: privacy@majorel.com with the subject line ‘Remove from studies reports and whitepapers’  ).

4.5 BUSINESS CUSTOMER SURVEY

4.5.1 DESCRIPTION AND SCOPE OF DATA PROCESSING

As part of our business customer relationships, we occasionally conduct customer surveys to measure satisfaction and improve our services. The customer survey is aimed at our business customers, but we regularly store your contact data in our customer database. We use your contact details to invite you to participate in the customer survey. Participation is voluntary and you have the possibility to communicate to us at any time that you no longer wish to receive an invitation to participate in customer surveys. Your contact data is no longer regularly required for the evaluation, so that the survey results consist of purely statistical information. It is then no longer possible to draw any conclusions about your person.

4.5.2 PURPOSE AND LEGAL BASIS OF DATA PROCESSING

The legal basis for processing your contact data is art. 6 sec. 1 lit. f GDPR. The legitimate interests lie in customer care and customer loyalty as well as the improvement of our services.

4.5.3 DURATION OF STORAGE OR CRITERIA APPLIED IN DEFINING THIS PERIOD

In principle, the survey results are stored for the duration of the business relationship. This does not apply if the survey results consist of purely statistical data.

4.5.4 OPTIONS FOR LODGING AN OBJECTION AND HAVING YOUR DATA REMOVED

You have the right to object to the processing of your contact data if there are reasons for this arising from your particular situation. If you would like to exercise your right of objection, please contact us at the address given under point 1.

4.6 APPLICATION FOR EMPLOYMENT

4.6.1 DESCRIPTION AND SCOPE OF DATA PROCESSING

Job advertisements are published on the website. Via the job advertisement you will be forwarded to our applicant portal, which collects and processes your data for recruitment purposes. Further information about data processing for recruitment purposes can be obtained by registering in the applicant portal.

In addition to applying via the applicant portal, you can also submit a short application on the website to Majorel Group Luxembourg S.A., based in Luxembourg, as well as to other affiliated companies of the Majorel Group Luxembourg S.A.. With the short application you can draw attention to yourself as a suitable talent without referring to a specific job posting. To assess your talent and contact you for suitable vacancies, you must provide your first and last name, e-mail address and telephone number as well as a small cover letter in the online application form provided for the short application. The short application is voluntary and can be revoked at any time with effect for the future.

4.6.2 PURPOSE AND LEGAL BASIS OF DATA PROCESSING

Your application data will be processed in order to assess your talent and to be able to contact you in suitable vacant positions. The legal basis is Art. 6 sec. 1 lit. a GDPR, by submitting your short application you give your consent to the data processing.

4.6.3 DURATION OF STORAGE OR CRITERIA APPLIED IN DEFINING THIS PERIOD

After your consent has been given, your short application will be stored for 1 year, unless you withdraw your consent prematurely. This shall not apply if statutory retention obligations oblige us to a longer storage period. Your consent, on the other hand, will be stored 3 years after deletion and/or revocation in order to be able to prove that we have complied with our legal obligations – to let you consent to data processing.

4.6.4 OPTIONS FOR LODGING AN OBJECTION AND HAVING YOUR DATA REMOVED

You can withdraw your consent any time without any formality by contacting Majorel Group Luxembourg S.A. 18, boulevard de Kockelscheuer , L-1821 Luxembourg, Email: privacy@majorel.com with the subject line ‘Remove application data’). The same applies to the individual companies in the group. The corresponding address can be found in Section 4.6.1 or in the consent.

4.7 WEBTRACKING

The website contains services that optimize user-friendliness and measure the reach of the website. Your access data (see section 2) is recorded and with the help of cookies (see section 3), the usage behavior is evaluated. In principle, personal identification is not required for web tracking, so that when your access data is entered, the stored IP address is either not used or is used exclusively shortened (shortened by the last octet) and pseudonymous user profiles are created. In principle, these are not merged with other data and you have the possibility of withdrawal at any time. The creation of personal user profiles takes place exclusively in exceptional cases and provided that you have given your consent.
The web tracking services are regularly provided by service providers who process the pseudonymous user profiles only in accordance with our instructions and not for their own purposes. This is ensured by means of data processing agreements. If the service providers are established outside the European Union or the European Economic Area (hereinafter referred to as “EU or EEA"), a so-called third country transfer takes place. This is permissible if you have consented to it or we have created a guarantee for a level of data protection appropriate to the European standard or the EU Commission has classified the respective third country as a safe third country.

The legal basis for collecting and analyzing pseudonym usage profiles follows from Art. 6 para. 1 lit. f GDPR / Section 15(3) German Telemedia Act (TMG). We have a legitimate interest in optimizing the user-friendliness of our website and performing marketing reach measurements.

The data collected and evaluated when using the web tracking services is usually stored until you object to their use.

4.8 EXTERNAL SERVICES AND CONTENT ON OUR WEBSITE

We integrate external services and content on our website. If you use one of these services or you are shown the content of third parties, communication data is exchanged between you and the provider of that service or content for technical purposes.

That provider may use your data for their own purpose. To the best of our knowledge and belief, we have configured the services or content of third-party providers who are known to use data for their own purposes so that communication for purposes other than rendering their content or services on our website is prevented or communication does not come about unless you actively decide to use the service. However, since we have no control over the data collected by third parties and its processing by them we are unable to make any binding statements pertaining to the purpose and scope of the processing of your data.

For further information on the purpose and scope of the collection and processing of your data, please refer to the privacy policy of the responsible provider (under data protection law) of the services or content integrated by us:

YouTube: https://support.google.com/youtube/answer/7671399

Google Maps: https://maps.google.com/help/terms_maps.html

4.9 WEBINARS

4.9.1     DESCRIPTION AND SCOPE OF DATA PROCESSING

You have the option of registering for webinars. Registering requires that you provide your first and last name and your email address. If you would like to be addressed as a company you can also optionally provide details on your company and your position there. After you have entered your details and given your consent to data processing, we use this information to send you confirmation of registration including a link enabling you to take part in the webinar. No other data processing takes place.

4.9.2     PURPOSE AND LEGAL BASIS OF DATA PROCESSING

Your participation in our webinars on current topics relating to our business segment enables us to inform you of current developments in our company or provide the results of scientific research. All webinars are free of charge. The legal basis for data processing follows from your consent pursuant to Art. 6 para. 1 lit. f GDPR.

4.9.3     DURATION OF STORAGE OR CRITERIA APPLIED IN DEFINING THIS PERIOD

As a general principle, the information provided by you is stored for two years. If, however, you revoke your consent before this two-year period lapses, your information will be deleted. After the information provided by you is deleted, your consent is stored for another three years so that we are able to comply with our statutory obligation of documenting proof that you gave your consent to the processing of your data. If you should revoke your consent, this is treated like your initial provision of consent in that it is stored for a period of three years upon the deletion of your information.

4.9.4     OPTIONS FOR LODGING AN OBJECTION AND HAVING YOUR INFORMATION REMOVED

When the processing of your personal data relies on Art. 6 para. 1 lit. b GDPR or Art. 6 para. 1 lit. f GDPR , you can withdraw your consent at any time. This can be done by way of a simple notice to this effect, without having to state any reasons. Any withdrawal only has effect for the future, meaning it does not affect the admissibility of data processing during the time prior to you withdrawing your consent. In the event you would like to withdraw your consent, please write to Majorel Group Luxembourg S.A. (18, boulevard de Kockelscheuer , L-1821 Luxembourg, Email: privacy@majorel.com with the subject line ‘Remove from webinars’).

4.10 NEWSLETTER

4.10.1     DESCRIPTION AND SCOPE OF DATA PROCESSING

Our website offers the possibility to subscribe to a free email newsletter. The data entered in the contact form will be collected by us processed with involvement of data processors and used to provide you with the requested information. By subscription we will collect a consent and refer to our Data Protection Notice, where we provide further information how we process personal data. There is no transmission of your data to third parties not involved in the direct provision of the newsletter. The only mandatory information for a subscription to our newsletter are a name (so we can address you accordingly) and a valid Email-address. These provided information will firstly be processed in order to verify the validity of the consented Email-address by means of an Opt-In. Additionally provided data are not mandatory.

4.10.2     PURPOSE AND LEGAL BASIS OF DATA PROCESSING

For the provision of the requested newsletter we will process your entered data accordingly. The legal basis for this is to be found in Art. 6 para. 1 lit. a GDPR.

4.10.3     DURATION OF STORAGE OR CRITERIA APPLIED IN DEFINING THIS PERIOD

For the time of your subscription we will store the data needed for the provision of the newsletter. The data will be processed only for this purpose and in order to demonstrate to authorities that we have obtained a valid consent for this processing. Where you withdraw your consent, we will delete all data about you, unless they are needed to demonstrate that we have complied with your withdrawal.

4.10.4    RIGHT TO WITHDRAW

You can unsubscribe from our newsletter at any time by using the unsubscribe button at the end of any newsletter or by sending an email with the subject “[Your email address] Unsubscribe [Name of the newsletter]” to contact@majorel.com. You will get a confirmation mail for your revoked subscription.

4.11 INVESTMENT RELATIONSHIP

4.11.1     DESCRIPTION AND SCOPE OF DATA PROCESSING

·         Newsletter

Our website offers the possibility to subscribe to an investment relationship newsletter leveraging tools provided by the EQS Group. If you subscribe to an email newsletter, for which you provided your name and email address, you will receive an email confirmation to your email address. Only after confirming the email your subscription is completed.

The data entered in the contact form will be collected by us and processed with involvement of EQS as a data processor and used to provide you with the requested information. By subscription we will collect a consent and refer to our Data Protection Notice, where we provide further information how we process personal data. There is no transmission of your data to third parties not involved in the direct provision of the newsletter.

·         Contact form

On our website you have the option of contacting us by way of a contact form. If you take advantage of this option, the information you enter in the contact form are disclosed to us and stored in a dedicated database. Depending on the reason you are contacting us your contact details are processed (with the assistance of service providers). If necessary for processing your request, this information may be shared with third parties (e.g. partner companies).

4.11.2     PURPOSE AND LEGAL BASIS OF DATA PROCESSING

·         Newsletter

On our website, we offer subscription to our newsletters and mailings in relation to investment relationship. For signing up for topic related newsletters and mailings your name and email address is necessary. For the provision of the requested newsletter we will process your entered data accordingly. The legal basis for this is to be found in Art. 6 sec. 1 lit. a GDPR.

·         Contact form

The legal basis for processing your contact details follows from Art. 6 para. 1 lit. f GDPR. We have legitimate interests in processing your request and in continued communication. If the purpose for your establishing contact with us is to enter into a contract with our company, the legal basis for processing your contact details follows from Art. 6 para. 1 lit. b GDPR.

4.11.3     DURATION OF STORAGE OR CRITERIA APPLIED IN DEFINING THIS PERIOD

·         Newsletter

For the time of your subscription we will store the data needed for the provision of the newsletter. The data will be processed only for this purpose and in order to demonstrate to authorities that we have obtained a valid consent for this processing. Where you withdraw your consent, we will delete all data about you, unless they are needed to demonstrate that we have complied with your withdrawal.

·         Contact form

The duration of the storage of the above data depends on the background of your contact. Your data will be deleted regularly if the purpose of the communication no longer applies and storage is no longer necessary (e.g. after processing your request).

4.11.4     RIGHT TO WITHDRAW

Your acceptance can be withdrawn anytime via a link at the end of each mailing or by sending an e-mail to contact@majorel.com. You will get a confirmation mail for your revoked subscription.

5. WHO COMES INTO POSSESSION OF MY PERSONAL DATA?

Within our company those who need access to your information for the purposes described in section 4 will be given access to it. Service providers contracted by us may also be given access to your information (“contract data processors”, e.g. data centers, mailing services for newsletters, web tracking). They are bound by our directives and must provide for data security and the confidential treatment of your information under the contract data processing agreements we have concluded with them.

No sharing of information with other recipients such as advertising partners, providers of social media services or credit institutions (“third parties”) takes place.

6. IS MY PERSONAL DATA PROCESSED OUTSIDE OF THE EU OR EEA (‘TRANSFER TO A THIRD COUNTRY’)?

The use of Google Analytics as described in section 3.3. above causes personal data to be transferred to a third country since the data centers of Google Inc. are located outside of the European Union and the European Economic Area (“EU or EEA”). Such transfers of personal data to third countries may result in your personal information being transmitted to a country which does not provide for the same standard of data protection as the EU or EEA. For this case, respective EU Standard Contractual Clauses have been signed. You can request a copy of these safeguards by contacting the addresses indicated in section 1 above.

7. WHAT DATA PRIVACY RIGHTS DO I HAVE?

You have the right to request access to your personal data that is currently stored by us. If this data is incorrect or not up to date, you have the right to request rectification. You also have the right to have your personal data erased and/or its processing restricted as provided for in Art. 17 and Art. 18 GDPR. You also have the right to request a copy of the personal data provided by you in a structured, commonly-used, machine-readable format (right to data portability).

If you have given your consent to the processing of your personal information for specific purposes, you can withdraw that consent at any time for the future. Your notice of revocation is to be addressed to us by writing to the contact address indicated in section 1.

Pursuant to Art. 21 GDPR, you also have the right for reasons relating to your specific situation to raise an objection to the processing of your data that is done on the basis of Art. 6 para.1 lit.f GDPR. You also have the right to lodge an objection to the processing of your personal information for direct marketing purposes. The same applies to automated processes involving the use of individual cookies, unless they are required for providing the functionality of our website.

You also have the right to lodge a complaint with the competent data protection authority. The authority responsible for us is:

Commission nationale pour la protection des données
1, avenue du Rock’n’Roll
L-4361 Esch-sur-Alzette

Telefon: +352 26 10 60-1

You also have the right to contact the data protection authority at your place of residence and request support in pursuing your matter.

8. TO WHAT EXTENT DOES AUTOMATED DECISION-MAKING TAKE PLACE?

We do not use any fully automated decision-making processes for any of the purposes set out in section 4.

9. IS PROFILING DONE?

No profiling takes place for any of the purposes set out in section 4.

10. HOW WE PROTECT YOUR PERSONAL DATA?

We take technical and organizational measures to protect your personal data and keep it confidential. We take extensive technical and organizational security measures, which are regularly reviewed and adapted to technological progress, to prevent manipulation or loss or misuse of your personal data. This includes, among other things, the use of recognized encryption methods (SSL or TLS).
However, we would like to point out that, due to the structure of the Internet, it is possible that the rules of data protection and the above-mentioned security measures are not observed by other persons or institutions that are not in our area of responsibility. In particular, data disclosed in unencrypted form – e.g. if this is done by e-mail – can be read by third parties. We have no technical influence on this. It is the user’s responsibility to protect the data he or she provides against misuse by encrypting it or in any other way.

11. WHAT HAPPENS IF THE PRIVACY POLICY IS CHANGED?

In the event of changes to the law or changes to our corporate processes, we may adjust this privacy policy accordingly. For this reason, we ask you to read this Privacy Policy regularly. You can access this Privacy Policy at any time by visiting our website and selecting the Privacy Policy link at the bottom of the page.

Date of this Privacy Policy: September 2021

PRIVACY POLICY APPLICABLE TO FACEBOOK FAN PAGES

I. DATA CONTROLLER

Majorel Group Luxembourg S.A.

18, boulevard de Kockelscheuer
L-1821 Luxembourg

Email: privacy@majorel.com

Majorel Group Luxembourg S.A. is accountable for the processing of the personal information described below (referred to hereinafter as “we”, “us”, “our”).

You can contact our data protection officer by writing to privacy@majorel.com with the subject line ‘For the attention of the Data Protection Officer’ or writing to us at the postal address indicated above by using the reference ‘For the attention of the Corporate Data Protection Department ’.

Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2 Ireland (“Facebook”) is also responsible for processing information. For more information, please consult: https://www.facebook.com/policy.php

You can contact Facebook’s data protection officer here: https://www.facebook.com/help/contact/540977946302970

You can find information on the processing of personal information by Facebook in your Facebook profile under the Settings menu – Privacy, or here: https://www.facebook.com/help/568137493302217

II. PROCESSING OF PERSONAL INFORMATION

1. GENERAL REMARKS

According to the GDPR, “personal data” (referred to below as “personal information”) means any information relating to an identified or identifiable natural person (“data subject”). Also pseudonymized information that cannot be directly linked to you, e.g. by way of a name or email address, is also personal information.

2. YOUR RIGHTS

You have the right at any time to request access to your personal information that is currently on file with us. If this information is incorrect or not up to date, you have the right to request that it be corrected. You also have the right to have your personal information deleted and/or its processing restricted as provided for in Art. 17 and Art. 18 GDPR. Where our processing by automated means of information provided by you is based on your consent or is the subject of a contract with you, you have the right to request a copy of this data in a structured, commonly-used, machine-readable format (right to data portability). If you want to exercise any of your rights, you can address these issues to the contact indicated in section 1 above.

If you have given your consent to the processing of your personal information, you can revoke this consent at any time with effect for the future. For information on your right to lodge an objection, see section III of this privacy policy.

You also have the right to lodge a complaint with the competent data protection authority. You can assert these rights by contacting the data controller.

3. OBLIGATION TO PROVIDE PERSONAL INFORMATION

As a general rule, you are not obligated to provide personal information to us. You must provide specific information only when concluding a contract (e.g. your email address or your name). Without this information we cannot enter into a contract with you or perform the contract. Facebook may impose other requirements on you. For more information, please consult https://www.facebook.com/policy.php.

4. DISCLOSURE OF PERSONAL INFORMATION TO THIRD PARTIES

Your personal information is not disclosed to third parties unless this is necessary for fulfilling obligations under a contract, we or the third party have/has an legitimate interest in disclosure, or your consent has been obtained. In addition, personal information may be shared with third parties in the event that we are obligated by virtue of operation of the law or by virtue of an enforceable directive of a governmental or other regulatory authority, or by order of a court or other authority of competent jurisdiction.

5. SERVICE PROVIDERS

We contract service providers in part for processing data. Access by service providers to your personal information is restricted to the extent necessary. As a general rule, service providers are engaged as contract data processors who are bound by our directives when processing data.

6. TRANSFER OF DATA TO NON-EEA COUNTRIES

Personal information may be transferred to third parties and contract data processors who are headquartered in non-EEA countries. In these cases, we ensure that the recipient provides for an appropriate level of data protection prior to transferring data. Some of the third parties engaged by us are headquartered in the USA. We have also concluded EU standard contractual clauses with various companies. Details can be obtained from our data protection officer on request.

7. DURATION OF STORAGE

We store your personal information for as long as it is necessary to provide our offerings and the associated services, or we have a legitimate interest in continued retention. In all other cases we delete your personal information with the exception of information (e.g. invoices) that we must retain for compliance with statutory retention periods (e.g. imposed by the tax code or commercial code).

8. PSEUDONYMIZED DATA PROCESSING

The processing of information described below primarily takes place on a pseudonymized basis. This means that we do not provide information to third parties that can be directly linked to you, e.g. by way of a name or email address, but rather a profile is created on the basis of an ID or cookie.

III. PROCESSING OF INFORMATION BY US OF USERS USING OUR FACEBOOK PAGES

The processing of information described below is for the purpose of operating our Facebook pages.

1. INSIGHTS

We receive statistical data from Facebook about the visitors to our Facebook pages by way of Facebook’s Audience Insights service. We are unable to link this information to any specific person. This feature enables us to better analyze our pages and adapt them to the needs and interests of our visitors. Facebook processes personally identifiable information in relation to this service on its own responsibility. For more information, please visit: https://www.facebook.com/iq/tools-resources/audience-insights. We need no legal basis for processing statistical or anonymized data.

2. INTERACTION ON OUR PAGES

We are also able to see when a specific Facebook user likes or subscribes to one of our Facebook pages. We are also able to link comments to individual users on our Facebook pages. The legal basis for this processing of information follows from Art. 6 (1) sentence 1 point b) and f) GDPR. We have a legitimate interest in interacting and continued communication with you. To the extent that the processing of information follows from Art. 6 (1) sentence 1 point f) GDPR, pursuant to Art. 21 (1) GDPR you have the right, for reasons relating to your particular situation, to lodge an objection at any time to the processing of your personal information with effect for the future by writing to our designated Data Protection Officer at the address indicated above by using the reference ‘For the attention of the Data Protection Officer’ or by writing to privacy@majorel.com with the subject line ‘For the attention of the Data Protection Officer’ and setting out your objection.

3. MONITORING

We review the comments on our Facebook pages for any inappropriate content. In so doing, it is readily clear under which Facebook profile a specific comment was posted. A link is made between the content of the comment, the timestamp created when the comment was posted, the user ID, the Facebook user name, and a reference to the preceding posts and comments. The result of a review may lead to the comment being hidden or the user being blocked. The legal basis for this follows from Art. 6 (1) sentence 1 point c) GDPR.

IV. PROCESSING OF INFORMATION PROVIDED BY YOU BY WAY OF A CONTACT FORM OR EMAIL

On our Facebook pages you have various options for contacting us for various purposes. We use the information provided by you in this manner solely to respond to the matter for which you have contacted us. Messages are deleted at the latest upon attending to your query, provided that we are not required to retain them for other reasons.

Last updated: July 2021