I. General Information
15 April 2022
Félix Giorgetti S.à R.L. is committed to protecting your privacy and to safeguarding your personal information. These rules of conduct relating to respect for privacy explain the type of personal information we collect and how we use, disclose and protect it.
What does this document cover?
These rules of conduct relating to respect for privacy apply to all personal data that you have provided to an employee or agent of Félix Giorgetti S.à R.L. and that Félix Giorgetti S.à R.L. may process in the course of its business activities.
Who is responsible for your data?
Felix Giorgetti S.à R.L. has appointed a personal data protection officer to guarantee compliance with the regulations.
Data controller & Data protection officer
- Name :
- SERTIC Jean-Marc
- 3, rue Jean Piret L-2350 Luxembourg
- +352 49 88 88 664
Change to these rules
We may change these rules of conduct relating to respect for privacy by posting an updated version of these rules. We will give you reasonable notice of any material changes.
II. Felix Giorgetti S.à R.L. principles relating to respect for privacy
Félix Giorgetti S.à R.L. takes privacy seriously. In accordance with the protection policy implemented within our company, the following five principles form the basis of our service approach to respect your privacy.
- Our company will always use your personal data in a fair and trustworthy manner and will take all reasonable steps to protect your information from misuse and to keep it secure.
- You have the right to be clearly informed about how we use your personal data and to request their correction or deletion. We will always be transparent with you about the data we collect and how we use it.
- We comply with all applicable data protection regulations and cooperate with the Luxembourg National Commission for Data Protection CNPD.
III. Rules of conduct of Felix Giorgetti S.à R.L. relating to respect for privacy
Implementation of your consent
When personal data are collected that do not result from a legal or contractual obligation, Félix Giorgetti S.à R.L. advises that their transmission is optional and implies, as soon as they are transmitted, consent to their further computerized processing by Félix Giorgetti S.à R.L. in compliance with the present conditions.
How do we collect your personal data?
In these rules of conduct relating to privacy, your “personal data” means one or more pieces of information that could be used to identify you. This generally includes information such as your name, address, user name, profile picture, email address and phone number, but may also include other information about your past or present professional activities. We may collect this information from a variety of sources, including:
- the information you give us directly
- information that we may collect through our partners, affiliates, subsidiaries and others.
How do we use your personal data?
We use your personal data for the overall management of the business of our organization, namely:
- to process the service contracts we have with you;
- to offer you services;
- to manage the invoicing of our services as well as your invoices within the framework of our accounting activity;
- to establish a customer database.
Where we collect personal data only for these purposes, we do not retain it for longer than is necessary to fulfil that purpose, unless we have to retain it for legitimate legal or contractual reasons.
To protect this data from accidental or malicious destruction, when we delete it from our services, we may not immediately delete residual copies from our servers or backup systems.
With whom do we share your personal data?
As a general rule, we do not share your personal data outside of Félix Giorgetti S.à R.L. However, in the context of the management of your personal file and the management of salaries and social charges, we communicate your data to carefully selected and controlled subcontractors.
We may also share your personal data with organizations if we believe that disclosure of the information is necessary for legal reasons in connection with a lawsuit.
Do we transfer your personal data to other countries?
We do not transfer any of your personal data to servers outside the European Union (EU), and we use subcontractors who commit to keep your data on EU territory. If this policy changes, it will be done in accordance with privacy laws and you will be notified.
How do we protect your personal data?
We take all reasonable precautions to keep your personal data secure and require any third-party handling or processing your personal data for us to do the same.
If Félix Giorgetti S.à R.L. collaborates with other companies, the choice of these companies will be only be made after a completed selection process. In this selection process, each service provider is carefully screened for suitability in terms of technical and organisational data protection skills. This selection procedure will be documented in writing and a contract for the processing of contract data will only be concluded if it complies with the identified security requirements, including European and national regulatory requirements.
Access to your personal data is restricted to prevent unauthorised access, modification or misuse, and is only allowed to our employees and agents who need it to do their job.
Specific use of your data
A cookie is a small text file that is sent to your browser when you visit a website. It can be sent either directly by the server hosting the website you are visiting or by a third-party server to which the website may have forwarded your request. By default, your browser keeps the cookie and returns it with each new request made to the server from which it originated. A cookie can only be read by the server that set it. A cookie may, for example, contain an identification number that allows us to recognise your browser when you interact with the website in question. It can also contain a simple “yes” or “no” answer to, for example, remember your choice in terms of cookies.
Cookies are used by Félix Giorgetti S.à R.L. to analyse the use of our website in an anonymous or pseudonymised form and to offer the user advanced functionalities.
Félix Giorgetti S.à R.L. offers you the possibility to give your consent as to the type of cookies allowed apart from those strictly necessary for the proper functioning of the site. The types of cookies and their purposes can be consulted upon consent.
Of course, this consent can be withdrawn or changed at any time by clicking on the following link:
Use of your data for information and advertising purposes
Besides providing our services, we also use your personal data to inform you about our marketing offers or promotions and to recommend other services that may be of interest to you.
More specifically, we may use your personal data to send you:
- a newsletter if you have explicitly chosen to receive it on our website, in one of our information emails by clicking on a link indicating that you wish to receive our newsletter, or by written consent by completing the consent form.
If you no longer wish to receive our information or newsletters by email, you can object at any time by contacting us by email or by using the link that you find in each of our emails or newsletters.
What are your rights and how do you exercise them?
If you have any questions, comments or concerns about how we handle your personal data, you can contact the Data Protection Officer directly.
You have the right to:
- request a copy of the personal data we hold about you,
- ask us to correct, update, or delete your personal information from our records, and
- to notify us of any misuse of your personal data.
If you believe that your personal data has not been processed in accordance with the law, you can contact the CNPD (National Commission for Data Protection) (www.cnpd.lu or email@example.com) and file a complaint with it.