Data Protection Notice
(Hereafter, the “Privacy Notice”)
What is the scope of this document?
We, at BETOCEE (BETOCEE S.ÀR.L., a société à responsabilité limitée, having its registered office at 25-27, Zone Industrielle Kehlen, L-8287 Kehlen, registered with the Luxembourg Business Register under number B203010, hereafter “BETOCEE”, “we”, “our” and “us”), have defined this Privacy Notice to explain and describe the personal data we collect, for what purposes we do it, as well as your privacy rights and the way you can exercise them.
This Privacy Notice applies to our use of Personal Data collected (as defined below) processed by us in relation to your use of services of brand strategy, brand philosophy, brand positioning and brand activation (hereafter, “BETOCEE Services”), of our website (www.BETOCEE.lu) (hereafter, the “Website”) and/or any interaction you may have with BETOCEE as:
- employee acting in the course of your employment contract;
- BETOCEE’s services provider providing services to BETOCEE;
- BETOCEE’s client using BETOCEE Services;
- third party browsing the Website and/or contacted by us or contacting us by any mean of communication.
Changes to the Privacy Notice
We may revise this Privacy Notice from time to time to keep it in line with changes in our business, services or applicable law, such as (but not limited to) the EU Regulation 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 (hereafter, the “General Data Protection Regulation”) and/or the Luxembourg Law of 1 August 2018 on the organisation of the National Data Protection Commission and the general data protection framework.
All changes to this Privacy Notice will be published on the Website. In case of substantial changes, we will also notify BETOCEE Services users, services providers, clients and employees by email. If you disagree with any future changes to this Privacy Notice, you should immediately stop using BETOCEE Services and the Website and contact BETOCEE.
Which types of personal data does BETOCEE collect about me?
BetoCee collects and processes Personal Data within the scope of this Privacy Notice (see question 1) concerning Services users, clients, services providers, employees and third parties browsing the Website and/or contacted by us or contacting us by any mean of communication (hereafter, the “Personal Data”).
We collect and/or process all Personal Data that you choose to communicate to us, such as your name, first name, civil and family status, home and/or office address, date of birth, nationality, social security number, profession, email address, mobile phone number, bank details and other financial data and, as well as other information we collect related to your use of our BETOCEE Services, our Website or your status as BETOCEE’s employee.
We also collect and/or process certain types of information automatically, whenever you interact with us in order to allow you to use the Website.
When you visit the Website, cookies may be installed on your browser software to obtain certain personal/usage data when your web browser accesses our Website.
Those usage data are the following:
- the Internet protocol (IP) address used to connect your computer or mobile device to the Internet;
- the location of your computer or mobile device during the use of our Website;
- interface controls; and
- system information.
For what purposes will BETOCEE collect and/or process my Personal Data?
BETOCEE collects/processes Personal Data for several reasons justified under the General Data Protection Regulation, such as:
- To provide and perform BETOCEE Services and Website, i.e. to prepare offers, provide services and operate the Website;
- To improve your experience on our Website, improve BETOCEE Services, as well as to develop BETOCEE Services and the Website;
- To handle your requests about BETOCEE Services and/ or the Website, to send newsletters and/or marketing emails, to inform you about our services, ask feedback about BETOCEE Services and/or inform you of changes and improvements;
- To manage risks, protect BETOCEE Services and Website, as well as verify that your usage of our services does not infringe any contractual clause, laws or regulations;
- To follow up on solicitation emails;
- To meet our legal, statutory and contractual obligations and to enable us to recruit, employ and train you in the course of your employment with us;
- To invoice BETOCEE Services and monitor payments; and
- To anonymise and encrypt Personal Data.
In addition to the above reasons, BETOCEE may require/ ask your consent in order to process your Personal Data for any other purpose, such as provide you with other personalised services offered by BETOCEE. In such case, BETOCEE will always ask for your prior consent before processing your Personal Data. You will give your consent by taking a positive action (such as ticking a box or sign a document) and will be free to withdraw your consent at any time and free of charge.
Who are the recipients of the Personal Data collected about me? Does BETOCEE share those data with third parties?
BETOCEE may share and disclose Personal Data with third parties (i.e. outside BETOCEE) on the following grounds:
With BETOCEE’s subcontractors
BETOCEE may share/ disclose Personal Data with its subcontractors that will perform services at BETOCEE’s direction and on its behalf (for example, a company providing accountant services). In this case, service providers will follow privacy rules at least as protective as those stated therein.
With BETOCEE’s clients and other third parties if the disclosure is required or permitted by law
BETOCEE may also share/ disclose Personal Data if required or permitted by law, such as, for example:
- in order to protect and/ or defend BETOCEE’s rights, including comply with a law or regulation, enforcing agreements or policies;
- to prevent fraud and/ or for safety reasons; and/or
- to protect the vital interests of a person.
With your consent
If one or some or your Personal Data might be shared to third parties other than specified above, you will receive notice and will have the choice not to allow your data to be shared.
BETOCEE may share your Personal Data when it collects your consent to do so.
Unless on the grounds specified above, BETOCEE will not share your Personal Data with third parties.
When BETOCEE transfers Personal Data to an authorised recipient that is registered outside the European Economic Area, it will ensure that such data is transferred in accordance with this Privacy Notice and that the transfer is made in accordance with the General Regulation on Data Protection.
How long does BETOCEE keep Personal Data?
BETOCEE only keeps Personal Data for the time strictly necessary in order to enable the use of our services and/or to fulfil the purposes identified above, and/or to comply with any legal or regulatory obligations. This may imply retaining Personal Data after the termination of your contractual relationship with BETOCEE for the period of time needed for BETOCEE to, for instance, demonstrate compliance with its legal or regulatory obligation, resolve dispute and/or enforce our agreements.
If you have questions regarding the specific period of storage of your Personal Data, please contact us by email at email@example.com.
Are my personal data safe with BETOCEE?
Your Personal Data are stored securely in accordance with the principles set out in General Data Protection Regulation.
BETOCEE uses physical (secured entry to the relevant buildings where the Personal Data are physically stored), administrative and software-based security safeguards (various security layers, such as passwords and restricted access rights) to provide reasonable protection for your Personal Data.
All your Personal Data digitally stored are protected by firewall and information access authorisation controls.
Who is responsible for processing Personal Data?
BETOCEE is the controller of Personal Data.
If you have any question on BETOCEE’s Privacy Notice or on our privacy practices that are not addressed in this Privacy Notice, please contact us by email (firstname.lastname@example.org) or by mail (BETOCEE S.ÀR.L., 25-27, Zone Industrielle Kehlen, L-8287 Kehlen).
What are my rights regarding my Personal Data?
Subject to limitations set out under European and Luxembourg law, you have the right of access, rectification, restriction, opposition, erasure and data portability of your Personal Data.
These rights may be exercised by contacting BETOCEE by email (email@example.com) or by mail (BETOCEE S.ÀR.L., 25-27, Zone Industrielle Kehlen, L-8287 Kehlen), together with a signed copy of your ID.
If you are not satisfied by the way we address your privacy concerns, you may also file a complaint with the CNPD (Commission nationale pour la protection des données), the Luxembourg supervisory authority for data protection or with the national supervisory authority for data protection in your country of residence.