Our policy on privacy and the protection of personal data
BY CK S.A. (last updated 28 March 2019)
The protection and security of personal data are important to CK S.A (hereinafter “CK”) and are a central element of our corporate compliance process. Naturally this also applies to the protection of data in connection with the use of our website; CK would like to provide you with information about this below. CK undertakes to handle your personal data in accordance with the regulations in force that are applicable to the processing of personal data, and in particular Regulation (EU) 2016/679 (hereinafter “EU Reg. 2016/679” or “GDPR”) which has been applicable since 25 May 2018, and the Luxembourg Act of 1 August 2018 on the organisation of the National Data Protection Commission, implementing the aforementioned regulation.
Data collection and processing
When you use our website, CK will not collect any personal data without your consent. Personal data means any information relating to an identified or identifiable natural person. In order to improve our website CK only collects certain communication and usage data which cannot be traced back to a specific individual.
I.1 Collection and processing of personal data
Certain services offered on our website can only be provided if CK is able to contact you (for example, requests for products or services). In this respect the ability to use these services depends on you providing specific personal data (contact details). CK collects, uses and processes these data exclusively to the extent necessary to provide you with the corresponding service. CK will neither use nor process these data in any way unless this is authorised in accordance with the statutory provisions or you have expressly consented to this. You can withdraw your consent at any time. To do this, please contact the person indicated in section VII.
You can download apps in the sub-domain “itraining”. However to do so you must first register on the portal. The following data will be collected as part of the registration process, and will be processed in order to prepare this request: company address, customer status, title, first and last name, phone and fax numbers, email address. Your email address will also be used for sending you a regular newsletter if you have explicitly consented to this.
CK collects personal data on the website www.ck-group.lu and/or on the occasion of organised events, when purchase orders are placed or during other contacts, in order to optimise our communication with you. CK undertakes always to provide you with the most interesting marketing content about the solutions from CK Group Charles Kieffer depending on your requirements and your profile. Hence CK stores the following information: name, (first and last name), email address, company name, company address, phone number, company size, area of business, function, workstation, number of IT positions and user behaviour. on the basis of emails sent and the user’s browsing activity on www.ck-group.lu
CK ensures that this information is only used for creating user profiles and is not shared with third parties or sold.
I.2 Collection and processing of communication and usage data
Use of Google Analytics
III. Recipient of the data
The main recipient of your data is CK.
CK might, however, transmit your personal data to particular subcontractors.
All of our subcontractors are based in the European Union and are in accordance with EU Reg. 2016/679. Upon written request CK will provide you with the full list of our current subcontractors. Our IT subcontractor only deals with our IT maintenance and the internal helpdesk, and no data are transmitted to him.
The data are stored on a server in Luxembourg.
International transmission of personal data
CK will not undertake any international transmission of your personal data. The data are stored on a local private server.
CK will retain your personal data for the purposes for which they were collected, generally for the duration of a contractual relationship or for no longer than one year, unless the law requires otherwise.
More particularly as far as recruitment is concerned, when CK processes your personal data following a job application, these data will be erased after the end of the recruitment process, in other words when the position has effectively been filled. However, if CK considers that there is a particular interest (such as, for example, a similar position that will shortly be vacant at CK) in retaining your personal data for a longer period, which cannot exceed one year, CK undertakes to ask for your consent to this retention.
When CK processes your personal data following an unsolicited application, CK will inform you of the retention of these data as follows:
CVs and cover letters: a retention period of no longer than 1 year for applicants that have not been selected, with the applicant being offered the option of having their data destroyed immediately.
Rights of data subjects
The right of access: the data subject has the right to obtain from the controller (CK) confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data. CK must be able to provide the data subjects with all the data concerning them.
The right to rectification: the data subject has the right to obtain from the controller (CK) without undue delay the rectification of inaccurate personal data concerning him or her.
The right to erasure: the data subject has the right to obtain from the controller (CK) the erasure of personal data concerning him or her without undue delay and CK has obligation to erase these personal data. If you encounter difficulties in exercising these rights, you also have the right to lodge a complaint with the national data protection supervisory authority.
You have the right to request information at any time on the data concerning you that are held by CK, their origin and recipients, and the purpose for which they have been stored. To do so please contact the person shown in section VIII.
VII. Identity of the controller and data protection officer
The controller is CK, represented by Mr Tom FRISCH.
CK has appointed a data protection officer whose role is to ensure that the provisions of the GDPR are complied with. The data protection officer ensures that the rights of the physical persons whose data are processed by CK are respected.
The data protection officer’s contact details are: firstname.lastname@example.org.
VIII. How to contact us
If you wish to inform CK of problems associated with data privacy or if you have any questions, comments or complaints, please email our data protection office at: email@example.com,
or contact them by post at:
CK Charles Kieffer Group
Tom FRISCH – Partner / General Manager – Administration
2, rue Léon Laval
Z.A. Am Bann
Tel: 00352 – 26 380 1
CK undertakes to deal speedily with complaints associated with the collection and use of your personal data.