II.Definitions

(a)  “Personal data”: all information about an identified or identifiable natural person (“the data subject”). A natural person is regarded as identifiable if he or she can be identified directly or indirectly, in particular by means of an identifier such as a name, an identification number, location data, an online identifier or one or more elements characterising the physical, physiological, genetic, psychological, economic, cultural or social identity of that natural person. Appendix 1 lists the Personal Data that the Processer will process in accordance with this agreement and the purposes for which the data are processed.

(b) “Processing”: any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

(c) “Controller”: a natural or legal person which, alone or jointly with others, determines the purposes and means of the processing of personal data.

(d) “Processor”: a natural or legal person which processes personal data on behalf of the Controller.

(e)  “Sub-processor”: the subcontractor appointed by the Processor to carry out part of the processing on behalf of the Controller.

(f) “Personal data breach”: a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed, also known as a “data leak” ;

(g) “Data Protection Legislation”: means any legislation applicable to the Processing of Personal Data, including without limitation, the Act of 1 August 2018 on the organisation of the National Data Protection Commission and the general data protection framework and Regulation 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter also referred to as “GDPR”)

 

III.Processing of personal data

Your:

• Use or visit of any website i) belonging to the VGD Luxembourg domain (https://lu.vgd.eu/), ii) managed by VGD Luxembourg, iii) referring to any of the foregoing, or iv) operated by a third-party on behalf of VGD Luxembourg (“Website”)(e.g. filling in contact forms, sending e-mail, telephone contact, newsletter subscription, chat, IP Address, event registration, etc.),
• Direct Interactions with VGD Luxembourg (e.g. certain sales and/or marketing interactions, face-to-face meetings, interactions at exhibitions, sales pitches, commercial gatherings, training session, webinars, social media interactions, events, email inquiries,…)
• Interactions (with (software) tools) related to the foregoing (e.g. direct marketing tools, account registrations, support, etc.)

will lead to the fact that Privacy Policy becomes effective to such Interaction.

VGD Luxembourg may be required to process certain Personal Data for the following purposes:

 

• Contract administration

The processing of Your first name, last name, address, email, telephone number, job title, company name, national registry number, billing information, and/or account actions & activities, in order to: negotiate, execute, renew and/or manage a contract with You, including in respect of the Service provided thereunder; process billing information and payments related thereto; and/or communicate with You in respect of the above (including sending (legal) notifications) and other contract related items.

This processing is based on article 6,1 b) GDPR: necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract. This processing is also based on article 6,1 c) GDPR: necessary for the purpose for compliance with a legal obligation to which the Controller is subject.

 

• Combating money laundering and the financing of terrorism

This purpose relates to the processing in application of the anti-money laundering laws, we are required to go through a client acceptance procedure. For all services where you wish to call upon us, we collect your personal identification data such as your name, address, phone number, email address, VAT number and data by scanning your ID card. VGD invokes legal obligations for the processing of the personal data.

This processing is based on article 6,1 (c) GDPR: necessary for compliance with a legal obligation to which the controller is subject.

 

• Lead Generation

This purpose relates to the processing of Your first name, last name, address, email, telephone number, job title and company name, depending on i) the personal data you publicly make or have made available (e.g. website, LinkedIn, memberships …),  ii) the type of interactions You have had with VGD Luxembourg and/or a third party allowed to share such personal data with VGD Luxembourg.

This processing is based on article 6,1 b) GDPR: necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract. This processing may also be based on article 6,1 f) GDPR: processing is necessary for the purposes of the legitimate interest pursued by the Controller.

 

• Supplier Management

The processing of Your first name, last name, address, email, telephone number, job title, company name, billing information, and/or account actions & activities, in order to: negotiate, execute, renew and/or manage a contract with You, including in respect of the Service provided thereunder; process billing information and payments related thereto; and/or communicate with You in respect of the above (including sending (legal) notifications) and other contract related items.

This processing is based on article 6,1 b) GDPR: necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract. This processing is also based on article 6,1 c) GDPR: necessary for the purpose for compliance with a legal obligation to which the Controller is subject.

 

• The use of the Website

In case You are making use of the Website, this purpose relates to the processing of Your:

1. first name, last name, job title, email, address information (all in case you would be making use of our Website under a user account)
2. IP address, the (web) page you were visiting before you came to the Website, information you search for on the Website, and, Your interactions with the Website
3. Necessary and Statistical Cookies

We do this in order to enable You to enjoy the use of, and easily navigate the Website; and/or better understand Your needs and interests in respect of our Website.

The processing of Personal Data for this Purpose is based on section 6,1 a) GDPR where the data subject “has given consent to the processing of his or her Personal Data for one or more specific purposes”.

 

• Direct Marketing

This purpose relates to the processing of Your first name, last name, address, email, telephone number, job title and company name, depending on the type of Interactions You have had in order to provide You with further information and offers from us or partners of VGD Luxembourg that VGD Luxembourg believes You may find useful or interesting, including newsletters, marketing, events or promotional materials and other information on Service and products offered by us or third parties.

This processing is based on article 6,1 f) GDPR: processing is necessary for the purposes of the legitimate interest pursued by the Controller.

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VGD Luxembourg only shares Your personal data with its employees and collaborators, Partners and third-party technology and service providers in respect of their Service. VGD Luxembourg only shares Your personal data with Other third parties to the extent VGD Luxembourg has good faith belief that such disclosure is reasonably necessary to (a) comply with a law, regulation or compulsory legal request from a public or law enforcement authority; (b) national security (c) protect the safety of any person from death or serious bodily injury; (d) prevent fraud or abuse; (e) as necessary to protect or enforce our legal rights & those of our collaborators as well as the integrity of our Service.

 

IV.Retention period

VGD Luxembourg retains your Personal data as long as your Personal Data is relevant for the purpose or for the duration of any retention period that is required by law.

 

V.Rights

As a data subject whose personal data are processed, you have a number of rights with regard to the processing operations carried out by VGD Luxembourg.

To exercise these rights, you should contact lut.laget@vgd.eu.VGD Luxembourg is obliged to respond to this request within a period of one month. You will only receive a response within the set period if you send your request for the exercise of your rights.

You have the following rights:

 

Right of inspection and access

You have the right to access your personal data and the right to check how they are being used. You may obtain a free copy of your available personal data at any time by simply making a request to this effect.

 

Right to correction, erasure and restriction

Except for those personal data that must be processed in connection with storage because of a legal obligation, you may indicate which personal data may not be processed at all or may only be processed for a limited number of processing operations. In addition, you may request that personal data which you do not wish to be processed in whole or in part, be deleted. You may also ask to check and, if necessary, correct your personal data.

 

Right to object, automated decisions and profiling

You may oppose the processing of your personal data at any time if your objection is based on serious and legitimate reasons. If you wish to oppose the use of your personal data for direct marketing purposes, you do not have to give any reasons for this.The processing of personal data is not carried out on the basis of automated decisions; in other words it is not carried out without human intervention. VGD Luxembourg does not engage profiling on the basis of the available personal data.

 

Right to withdraw consent

If the processing of your personal data is based on consent you have given, you may withdraw this consent at any time.

 

Right to portability

Under the conditions stipulated in the GDPR, you have the right to obtain your personal data in a structured, commonly used and machine-readable form. You may ask VGD Luxembourg to transfer your data in this way to another Controller.

 

Complaints

If you believe that your rights as a data subject are being infringed by or during the processing of your personal data, you have the right to make a complaint to the Data Protection Supervisor (Commission Nationale pour la Protection des Données (CNPD), 1, Avenue du Rock'n'Roll, L-4361 Esch-sur-Alzette, T +352 26 10 60 1; F +352 26 10 60 29), without prejudice to any other possibility of initiating a judicial review or seeking a judicial remedy.

 

VI.Transfer to third parties

VGD Luxembourg undertakes not to sell, rent, distribute or otherwise disclose your personal data to third parties, unless the communication is made to the third party under a legal obligation. In exceptional cases, mandatory laws oblige VGD Luxembourg to transfer your personal data to the competent government authorities. Likewise, a court order may require VGD Luxembourg to communicate personal data to people authorised by the order to inspect the personal data concerned.VGD Luxembourg makes an exception to its non-disclosure undertaking in the event of a partial or complete reorganisation or a transfer of the company’s business operations. In such cases, your personal data will be conveyed along with the business operations to the third parties involved in the transfer and in the confidential negotiations prior to the transfer.

As far as possible, VGD Luxembourg will inform you of the transfer to the aforementioned third parties.

 

VII.Security and confidentiality

VGD Luxembourg guarantees that the processing of your personal data takes place in an appropriate, correct and secure manner. If you wish, you will be informed in a transparent manner about the processing procedures and the technical and organisational measures taken to prevent any loss, falsification or unlawful alteration of or unlawful access to your personal data.

 

VIII.Modifications

VGD Luxembourg reserves the right to change this policy. You should review this Privacy Policy often to stay informed of changes that may affect You.