Privacy Policy

This privacy policy (the “Privacy Policy”) governs the manner in which SK INFORMATIK SARL, a Luxembourgish limited liability company (société à responsabilité limitée) with registered office at 21, Av. de la Faïencerie, L - 1510 Luxembourg, GRAND DUCHY OF LUXEMBOURG, registered with the Luxembourg Trade and Companies Registry under number B227024 or any of its affiliated companies (“SK INFORMATIK”) collects, uses, maintains and discloses information collected from clients and/or users (each, a "User" or “Users”) of its websites, mobile applications or any other services (the "Services").

Compliance with Data protection Law

SK INFORMATIK SARL acknowledges and undertakes to comply with the laws and regulations governing the processing of personal data, including, but not limited to, the 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 (“GDPR”) and any other national applicable laws or regulations governing the processing of personal data in the framework of the Services.

Data protection officer

SK INFORMATIK SARL acts as data controller and has appointed a data protection officer.

The data protection officer appointed by SK INFORMATIK SARL shall be contacted by using the following information:

Address: 21, Av. de la Faïencerie, L - 1510 Luxembourg, LUXEMBOURG
Telephone: +352 27720220
Email: info[at]sk-informatik.lu

Personal identification information

SK INFORMATIK SARL may collect personal identification information from Users in a variety of ways, including, but not limited to, when Users visit SK INFORMATIK SARL websites, register on such websites, fill out a form, sign a contract, purchase a product and in connection with other activities, use applications and benefit from Services proposed by SK INFORMATIK SARL. Users may be asked for, as appropriate, name, date of birth, email address, mailing address, phone number, etc. In the framework of certain Services, SK INFORMATIK SARL may also collect data relating to energy consumption of the Users in order to benefit from such particular Services.

Non-personal identification information

SK INFORMATIK SARL may collect non-personal identification information about Users whenever they use an SK INFORMATIK SARL website or application or other online service. Non-personal identification information may include technical information about Users means of connection, such as the operating system and the Internet service provider utilized, geographical information such as country of origin, behavioural information such as time spent on site, as well as further non-personal analytical data to improve customer experience, products and services.

Each User recognizes and accepts that the performance of the Services may depend on the collection and processing of personal identification information and non-personal identification information.

Web browser cookies

SK INFORMATIK SARL may use « cookies » to improve the User’s experience in regard of the Services. In that case, the User’s Internet navigator places cookies on his hard drive to gather a certain set of information used to customize the navigation in the framework of the Services, thus enabling certain unique functionalities.

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!!!! COOKIES !!!!

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How SK INFORMATIK SARL uses collected information

Principally, personal and non-personal identification information is used to provide the Users with the Services and to insure a full efficiency of the Services they have registered for or they requested in any other manner.

In this framework, SK INFORMATIK SARL may collect and use Users’ personal and non-personal identification information for the following purposes:

• To improve Services: Information Users provided will help SK INFORMATIK SARL to respond to certain Users’ requests.

• To personalize User experience: SK INFORMATIK SARL may use non-personal identification information to understand how Users as a group use SK INFORMATIK SARL’ Services.

• To improve SK INFORMATIK SARL’ websites and other internet presence as well as other communication tools or tools for specific Services: SK INFORMATIK SARL may use feedback that Users provide to improve its products and services.

• To send periodic emails and other text messages and/or notifications: SK INFORMATIK SARL may use the email address or mobile phone number provided by Users to respond to inquiries, questions, and/or other requests. If Users decide to opt-in to SK INFORMATIK SARL notification list, they will receive periodic information that may include energy summaries (for certain Services), company news, updates, related product or service information, private sales, information from SK INFORMATIK SARL service providers on joint projects etc.(the “Periodic Information Service”). For the case that, at any time, Users would like to unsubscribe from the Periodic Information Service, SK INFORMATIK SARL includes detailed unsubscribe instructions at the bottom of each such email or other text message.

How SK INFORMATIK SARL protects personal identification information

SK INFORMATIK SARL adopts appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of Users’ personal identification information within the limits of SK INFORMATIK SARL’ role with respect to the relevant Services (as certain specific services might be rendered by third parties).

Sharing personal information

SK INFORMATIK SARL does not sell, trade, or otherwise transfer to third parties Users’ personal identification information. However each User accepts that his/her personal identification information can be transmitted to website hosting and editing partners and other sub-contractors who assist SK INFORMATIK SARL in providing the Services, conducting its business, or servicing the User, so long as those sub-contractors undertake to process the information only according to SK INFORMATIK SARL’ instructions and to comply with the applicable law regarding the protection of personal identification information. SK INFORMATIK SARL may also release User’s personal identification information when it believes that such release is necessary to comply with the law, enforce its websites’ general terms of use, or protect its or others' rights, property, or safety.

However, Users non-personal identification information may be provided to third parties for marketing, advertising, or other uses.

Changes to this Privacy Policy

SK INFORMATIK SARL has the discretion to update this Privacy Policy at any time. SK INFORMATIK SARL will therefore revise the “last update date” at the bottom of this page. SK INFORMATIK SARL encourages Users to frequently check this page for any changes. Users acknowledge and agree that it is their responsibility to review this Privacy Policy periodically and become aware of modifications.

Data Retention

SK INFORMATIK SARL takes all reasonable measures to ensure that User’ personal data are processed for the minimum period necessary for the purposes set out in this Privacy Policy. The Personal Data will be retained by SK INFORMATIK SARL according to the following criteria:

1. as long as SK INFORMATIK SARL maintain an ongoing relationship with the User (e.g., where the User is a recipient of SK INFORMATIK SARL’ services, or is lawfully included in SK INFORMATIK SARL’s mailing list and has not unsubscribed);

2. as long as the User’ personal data are necessary in connection with the purposes set out in this Privacy Policy, for which SK INFORMATIK SARL has a valid legal basis

3. until the expiry of a period of two (2) months following the end of any applicable limitation period under applicable law; and

4. with the User’ prior consent, until the expiry of any additional retention period.

SK INFORMATIK SARL undertakes to delete or to anonymise the User’ personal data upon expiry of the retention period as described above.

Data Security and data transfer

SK INFORMATIK SARL has implemented appropriate technical and organizational security measures designed to protect the User personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of processing, in accordance with applicable law.

The User is responsible for ensuring that any personal data that he/she send to us are sent securely.

SK INFORMATIK SARL does not transfer personal data to any third country nor to any international organisation, except as the case may be on the basis of:

• adequacy decisions;

• suitable Standard Contractual Clauses; or

• other valid transfer mechanisms under GDPR.

Data Accuracy and minimization

We take reasonable measures:

• to ensure that the User’ personal data are accurate and, where necessary, kept up to date and accurate; and

• that the User’ personal data are collected on an as needed basis in connection with the purposes set out in this Privacy Policy.

Data subject rights

Each User benefits under data protection law from a right of access, modification and opposition to the processing of its personal data, a right to erasure and a right to portability of its personal data by sending an email to info[at]sk-informatik.lu.Those rights may only be exercised within the limits of any contractual or legal obligation. Each User has also a right to lodge a complaint with the Luxembourg supervisory authority, namely the Commission nationale pour la protection des données (https://cnpd.public.lu/fr.html).

Acceptance of these terms

By using the Services, Users confirm their acceptance of this Privacy Policy. If a User does not agree with this Privacy Policy, SK INFORMATIK SARL recommends to such User that he shall not use the Services. The continued use of the Services following the posting of changes to this Privacy Policy will be deemed as an acceptance of those changes.