Privacy Policy (15-01-2025)
The Privacy Policy of Flexcom S.A.R.L. (hereinafter referred to as the “Privacy Policy”) provides information on the collection, use, sharing, and processing of personal information by Flexcom S.A.R.L. (hereinafter referred to as “Flexcom” or “we”). This Privacy Policy covers your use of our website as well as the processing of your personal information (as defined below) when we provide services such as technical support, Cloud, or other offerings.
This Privacy Policy was updated on 15-01-2025. However, it is subject to further modification to comply with legal requirements or to address the needs of our ever-evolving business.
This Privacy Policy complies with the applicable regulations regarding the processing of personal data, in particular Regulation (EU) 2016/679 (hereinafter “GDPR”), as well as all applicable Luxembourg regulations deriving from it.
In this Privacy Policy, the terms “personal information” or “personal data” refer to information relating to an identified or identifiable individual. For example, personal information may include, depending on the service in question, your name, email address, business contact details, or information collected during your interactions with us through our website.
Flexcom does not process personal data without your consent, whether in the context of providing any service, when you use our website, or when you contact us through other means. Specific provisions regarding data processing may be applied based on the provision of one or more specific services. In such cases, please also refer to the terms of use for these services.
I – Collection and Processing of Personal Data
Certain services offered on our website can only be provided if Flexcom is able to contact you (e.g., product requests or additional information inquiries). Accordingly, using these services depends on you providing specific personal data (contact details). Flexcom collects, uses, and processes this data only to the extent necessary to provide the corresponding service. Flexcom does not use or process data in any way except as authorized by legal provisions or if you have expressly consented. You may revoke your consent at any time by contacting the person indicated in Section IX.
In order to view a demonstration, gain access to our Partner Portal, download content, or participate in webinars, users must transmit the following personally-identifying information:
- First and last names;
- E-mail address;
- Company name
Users may add other Personal Data to their profile (telephone number, job title, telephone number, etc.). Flexcom will never collect, or process Personal Data directly or indirectly related to race, health status, sexual orientation, or political, philosophical, or religious belief.
If you have explicitly consented, your email address will also be used to send you regular newsletters. Flexcom collects personal data on www.flexcom.lu, www.flexcom.ch, and www.flexcomlabs.com, and/or during organized events to optimize communication with you.
Flexcom stores the following information: name, first name, email address, company name, company address, phone number, company size, industry, role, job position, user behavior based on sent emails, and navigation on www.flexcom.lu.
Flexcom ensures that this information is used solely for creating user profiles, is not shared with third parties, and is not commercialized.
We may also process personal information for the following purposes:
- To communicate and respond to your questions and inquiries.
- To analyze, develop, improve, and optimize the use, functionality, and performance of our website, products, and services.
- To manage the security of our website, networks, and systems.
- To comply with laws and regulations.
When interacting with our website or using our services, you may also link or connect to websites, services, or other features that are not part of our offerings. Activating these features involves third parties other than Flexcom processing your information. Flexcom has no control over these third parties’ activities. We strongly encourage you to review their privacy policies before using these features.
II – Use of Cookies
To make our website attractive to visitors and enable certain features, Flexcom uses cookies on various pages. These are small text files stored on your device. Most cookies used by Flexcom are deleted at the end of each browsing session (called session cookies).
Other cookies remain on your device and allow Flexcom to recognize your browser upon your next visit (persistent cookies). You can configure your browser to notify you when cookies are saved, allow you to decide whether to accept cookies on a case-by-case basis, or refuse all cookies. If you choose not to accept cookies, some features of our website may be limited.
III – Data Recipients
The primary recipient of your data is Flexcom.
Flexcom may, however, share your personal data with certain subcontractors.
All our subcontractors are based in the European Union and are committed to complying with the GDPR. Upon written request, Flexcom will provide a complete list of its current subcontractors. Flexcom and/or the subcontractors have implemented 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 unlawful processing.
IV – International Transfers of Personal Data
Generally, Flexcom does not carry out international transfers of personal data. Data is stored on a local, private server.
However, Flexcom or a third party may transfer, access, and store personal data related to service provision within the European Economic Area if necessary for performing specific services.
V – Data Retention
Flexcom retains your personal data for the purposes for which it was collected, generally for the duration of a contractual relationship or a maximum of 10 years unless certain data must be retained for less than 10 years due to legal obligations.
When processing your data for an online job application, this data will be deleted at the end of the recruitment process. If Flexcom deems it necessary to retain your data longer (e.g., for a similar upcoming position), we will request your consent for retention not exceeding two years, with the option for you to request immediate destruction.
VI – Data Breach Notification and Incident Management
Flexcom promptly investigates and addresses incidents that suggest or indicate unauthorized access to or use of personal information related to specific services.
If Flexcom identifies and determines that an incident involving personal information related to specific services constitutes a security breach resulting in unlawful appropriation, accidental or unlawful destruction, loss, or alteration, or unauthorized disclosure or access to personal information related to specific services that are transmitted, stored, or otherwise processed on third-party systems made available by Flexcom, thereby compromising the security, confidentiality, or integrity of said personal information, Flexcom will notify you of the breach promptly.
Once the information related to the breach is collected or becomes reasonably accessible to Flexcom, and insofar as permitted by applicable law, Flexcom will provide you with any additional relevant information it has about the breach.
VII – Rights of Data Subjects
- Right of Access: The data subject has the right to obtain from the data controller (Flexcom) confirmation as to whether or not personal data concerning them is being processed and, where it is, access to such personal data. Flexcom must be in a position to provide data subjects with all data concerning them.
- Right to Rectification: The data subject has the right to obtain from the data controller (Flexcom), without undue delay, the rectification of inaccurate personal data concerning them.
- Right to Erasure: The data subject has the right to obtain from the data controller (Flexcom) the erasure, without undue delay, of personal data concerning them, and Flexcom is obliged to erase such personal data. In case of difficulties encountered while exercising these rights, you also have the right to lodge a complaint with the National Commission for Data Protection.
- Right to Restriction of Processing: This includes the right to request the suspension of the processing of your data: when you identify inaccuracies in the data, pending verification by the data controller; if the processing is unlawful and you prefer restriction over erasure; or if you need the restriction of processing to establish, exercise, or defend your legal claims. In case of restriction, your data can no longer be processed.
- Right to Data Portability: The data subject has the right to retrieve the data they have provided in a structured, commonly used, and machine-readable format from Flexcom and transmit it to a third party, if the processing is based on their consent or a contract between them and Flexcom and was carried out using automated processes.
- Right to Object: You have the right to object at any time to the processing of your data for the future. Your objection applies only to future processing and not to past processing. If you object, Flexcom will immediately stop processing your data. However, your objection does not apply where processing is required by law.
You have the right to request information at any time about the data Flexcom holds about you, its origin, its recipients, and the purpose for which it is stored. To do so, please contact the person mentioned in Section IX. They 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 applicable laws.
If you encounter difficulties while exercising these rights, you can lodge a complaint with the National Commission for Data Protection (www.cnpd.lu).
VIII – Identity of the Data Controller and Data Protection Officer
The data controller is Flexcom. The contact details are as follows:
FLEXCOM
12, Avenue du Rock’n’Roll
L-4361 Esch/Belval
Tel: +352 26 15 11 415
Email: rgpd@flexcomlabs.com
Flexcom has appointed a Data Protection Officer (DPO) responsible for ensuring compliance with GDPR provisions. The contact details are as follows:
FLEXCOM
12, Avenue du Rock’n’Roll
L-4361 Esch/Belval
Tel: +352 26 15 11 415
Email: dpo@flexcomlabs.com
The Data Protection Officer ensures the protection of the rights of individuals whose data is processed by Flexcom.
IX – How to Contact Us
If you wish to raise issues related to data privacy or if you have questions, comments, or complaints, please contact:
- The data controller, Flexcom, via this email address: rgpd@flexcomlabs.com
- Or exclusively our Data Protection Officer via this email address: dpo@flexcomlabs.com
Flexcom is committed to handling complaints related to the collection and use of your personal data with diligence.
Flexcom reserves the right to amend, modify, and update this Privacy Policy at any time. Please check our website regularly to ensure you are aware of the most recent version.