C.K. S.A.’s privacy policy (hereinafter referred to as “Privacy Policy”) provides information about the collection, use, sharing and processing of personal information by C.K. S.A. (hereinafter “C.K.” or “we” or “us”). This Privacy Policy includes your use of our website but also any processing of your personal information (as defined below) when we provide services such as technical support, Cloud or other services.

This Privacy Policy was last updated on 26-06-2024. However, it may be amended from time to time in the future, in particular in order to comply with legal requirements or to meet the evolving needs of our business.

 

This Privacy Policy complies with the current regulations applicable to the processing of personal data and, in particular, with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (hereinafter “GDPR”) as well as any Luxembourg laws and regulations deriving therefrom.

In this Privacy Policy, the term “personal information” or “personal data” refers to information that relates to an identified or identifiable natural person. For example, this personal information may include, depending on the type of service concerned, your name, e-mail address, business contact information, personal information about your employees, collaborators, customers, or information collected during your interactions with us via our website.

C.K. does not process any personal data without your consent in connection with the provision of any service, when you use our website or when you contact us by any other means. Specific data processing arrangements may be put in place depending on the provision of a particular service or services. In this case, you should also refer to the general terms and conditions of use of these services.

 

I – Collection and processing of personal data

 

Certain services offered on our website can only be provided if C.K. is able to contact you (e.g. requests for products or services). In this respect, the possibility to use these services depends on your provision of specific personal data (contact information). C.K. collects, uses and processes this data only to the extent necessary to provide you with the corresponding service. C.K. does not use or process the data in any way whatsoever unless this is permitted in accordance with the legal provisions or you have expressly consented to this. You can revoke your consent at any time. To do so, please contact the contact person indicated in section IX.

You can download applications in the sub-domain “itraining”. However, in order to do so, you must first register on the itraining portal. The following data will be collected as part of the registration process and will be processed in order to prepare the application: company address, customer status, title, first and last name, telephone and fax number, e-mail address. C.K. collects and processes personal data on www.ck-group.lu and/or on the occasion of organized events, in order to optimize our communication with you.

C.K. is committed to always provide you with the most interesting marketing content on C.K. solutions (services and products) according to your needs and profile. If you explicitly consented and authorized us to this, we may, to that end, send you unsolicited or unwanted commercial communications (including newsletters) to the e-mail address, postal address and/or telephone number (sms, call) that you communicated to us through filed forms, registration on the itraining portal, or by other means. To provide you with the aforementioned marketing content, C.K. stores and processes the following information: name, first name, e-mail address, company name, company address, telephone number, company size, business sector, function, workstation, user behaviour on the basis of the e-mails sent and on the use of the following website :  www.ck-group.lu.

C.K. ensures that this information will only be used for the creation of user profiles, will not be shared with third parties and will not be commercialized..

We may also process personal information for the following purposes:

• communicating and responding to your questions and inquiries ;
• to analyze, develop, improve and optimize the use, function and performance of the website and our products and services ;
• manage the security of our website, networks and systems;
• comply with laws and regulations.

 

By interacting with our website or using our services, you may also be able to link or connect to websites, services or other features that are not part of our services. As a result of the activation of these features, third parties other than C.K. S.A. will process your information. C.K. S.A. has no control over the activities of these other parties. We strongly encourage you to consult their privacy policy before using these features.

 

II – Use of Cookies

In order to make our site attractive to visitors and to enable the use of certain functions and to provide you with the most interesting marketing content on C.K. solutions (services and products) through unsolicited or unwanted commercial communications, C.K. uses cookies on different pages. These are small text files stored on your final device. Most of the cookies that C.K. uses are deleted at the end of each browser session (so-called session cookies).

Other cookies remain on your device and enable C.K. to detect your browser on your next visit (persistent cookies). You can configure your browser to inform you when cookies are saved, to allow you to decide whether to accept cookies on a case-by-case basis or never to accept cookies. If you choose not to accept cookies, the functionality of our website may be restricted.

For more information, please refer to our cookie policy.

 

III – Recipient of data

The main recipient of your data is C.K.

However, C.K. is likely to communicate your personal data to certain subcontractors.

All our subcontractors are established in the European Union and are committed to respecting the GDPR. Upon written request, C.K. will provide you with a complete list of its current subcontractors. C.K. and/or the subcontractors have put in place technical, physical and organizational measures to protect personal information against accidental or unlawful destruction, accidental loss, damage, alteration, unauthorized disclosure or access, as well as any other form of unlawful processing.

 

 IV – International transfers of personal data

Generally, C.K. does not transfer personal data internationally. The data is stored on a local and private server.

Nevertheless, C.K. or any other third party may transfer, consult and store personal data in connection with the provision of services within the European Economic Area if this is necessary for the execution of specific services.

 

V – Retention of data

C.K. will retain your personal data for the purposes for which it was collected, generally for the duration of a contractual relationship or for a maximum period of 10 years, except for certain data for which the law requires a retention period of less than 10 years.

When C.K. processes your personal data following an online application, this data will be deleted as soon as the recruitment procedure is completed, i.e. as soon as the position is actually filled. However, if C.K. considers that there is a particular interest (such as a similar position soon to be opened within C.K.) to keep your personal data for a longer period of time, not exceeding two years, C.K. undertakes to ask for your consent for this retention, with the possibility for the unsuccessful candidate to request the immediate destruction of his file.

 

VI – Data breach notification and incident management

C.K. examines and deals with incidents that suggest or indicate unauthorized access or use of personal information related to specific services as soon as possible.

If C.K. becomes aware of and determines that an incident involving personal information related to specific services is considered a security breach resulting in misappropriation or accidental or unlawful destruction, loss or alteration, unauthorized disclosure or access to personal information related to specific services transmitted, stored or otherwise processed on third party systems made available by C.K., compromising the security, confidentiality or integrity of such personal information related to specific services, C.K. will promptly notify you of such breach.

As information relating to the breach is collected or becomes reasonably available to C.K., and to the extent permitted by applicable law, C.K. will provide you with additional relevant information it has about the breach.

 

VII – Rights of data subjects

• The right of access: the data subject has the right to obtain confirmation from the data controller (C.K.) whether or not personal data concerning him/her are processed and, if so, access to such personal data. C.K. must be in a position to communicate to the data subjects all the data concerning them.
• The right of rectification: the data subject has the right to obtain from the data controller (C.K.), as soon as possible, the rectification of the personal data concerning him/her that are inaccurate.
• The right to erasure: the data subject has the right to obtain from the data controller (C.K.) the erasure, as soon as possible, of personal data concerning him/her and C.K. has the obligation to erase these personal data. In the event of difficulties in exercising these rights, you also have the right to lodge a complaint with the National Commission for Data Protection.
• The right of limitation of the processing: i.e. the right to request the interruption of the processing of your data: when you notice the inaccuracy of a data while waiting for the data controller to verify it; if the processing is unlawful and you prefer a limitation to an erasure; if you need the limitation of the processing for the ascertainment, exercise and defence of your rights in court. In case of limitation, your data may no longer be processed.
• The right to data portability: the data subject has the right to retrieve the data he has communicated in a structured, commonly used and readable format to C.K. and to pass it on to a third party, if the processing is based on his consent or a contract between him and C.K. of the data and it has been carried out by means of automated processes.
• The right of opposition: you have the right to oppose at any time to the processing of your data for the future. Your opposition is only valid for the future and not for the past. In case of opposition, C.K. will immediately stop the processing of your data. Your objection does not apply, however, if the processing is provided for by law.

You have the right to request information at any time about the data C.K. holds about you, their origin and recipients and the purpose for which they are stored. To do so, please contact the contact person indicated in section IX. She will investigate and attempt to resolve complaints and disputes arising from the use and disclosure of personal data in accordance with this privacy policy and in accordance with applicable laws.

In the event of difficulties in exercising these rights, you may file a complaint with the National Data Protection Commission (https://cnpd.public.lu/en/particuliers/faire-valoir/formulaire-plainte.html).

C.K. does not take decisions that would be based solely on automated processing which are susceptible to produce legal effects that would concern you or similarly significantly affect you as a data subject. Decisions based on automated processing are decisions that are taken with regards to a data subject, exclusively by means of algorithms applied to its personal data, without any human being intervention in the process (e.g., a C.K. employee).

 

VIII – Identity of the data controller and data protection officer

The data controller is C.K., represented by Mr. Tom FRISCH, member of the management. His contact details are as follows:

CK Charles Kieffer Group (C.K. S.A.)

Mr. Tom FRISCH – Partner / General Manager – Administration

2 Léon Laval Street

Z.A. Am Bann

L-3372 Leudelange

Tel: 00352 – 26 380 1

rgpd@ck.lu

 

C.K. has appointed a data protection delegate whose mission is to ensure compliance with the provisions of the RGPD. The delegate is

Gabriel BLESER, Attorney at Law.

The data protection delegate ensures that the rights of individuals whose data is processed by C.K. are respected.

He can be contacted at dpo@ck.lu and gabriel.bleser@barreau.lu

 

XI – How to contact us

If you wish to report data privacy issues or if you have any questions, comments or complaints related to your personal data, please contact :

– the data controller C.K. via the following address: rgpd@ck.lu

– or only our data protection officer via the following address: dpo@ck.lu or gabriel.bleser@barreau.lu

C.K. undertakes to handle complaints in connection with the collection and use of your personal data with due diligence.

C.K. reserves the right to correct, modify and update this privacy policy at any time. Please check our site regularly to ensure that you are aware of the most recent version.