1 – Introduction
This Personal Data Protection Policy (hereby “Policy”) applies to all Users of SEVES Group websites (Seves.com, Sediver.com), hereafter referred to as “SEVES”.
SEVES may process Personal Data (as defined below) in the conduct of its activities.
The purpose of this "Personal Data Protection Policy" is to inform all those individuals involved about how SEVES collects and uses Personal Data, and about the means that Users can activate to exercise their rights regarding the use of their Personal Data.
This policy also aims at defining the commitments made by SEVES regarding the respect of the principles of European regulation n° 2016/679, in force since May 25, 2018, known as the General Data Protection Regulation (“GDPR”).
2 – Scope and Definitions
This Policy sets out the principles and guidelines for the protection of Personal Data; including all types of Personal Data processed by SEVES through its websites.
SEVES collects Personal Data through online forms and session or persistent cookies (see Article 6 below).
3 – Collected Personal Data
- “Data processing” means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
- “Data controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data; where the purposes and means of such processing are determined by the European Union or Member State law, the controller or the specific criteria for its nomination may be provided for by the European Union or Member State law.
- “Data processor” means a natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Data controller.
- “Individual” or “User” means any natural person who can be identified, directly or indirectly.
- "Personal Data" means any information directly or indirectly identifying a natural person (e.g. name, registration, phone number, photograph, date of birth,etc.) and "sensitive data", means any information concerning trade union membership, health or any information as defined by the RGPD as sensitive.
The collection of Personal Data is limited to data strictly necessary for the purpose set out in Article 4 below. SEVES may collect Personal Data including, but not limited to:
- Last name and first name;
- Postal Address;
- Email address;
- Phone number(s);
- University, diplomas and classes attended;
- Data related to professional career;
- Any other Personal Data relevant for the purpose set out below.
The User can provide none, some or part of its Personal Data. No Personal Data is collected without the consent of the User. However, if a User decides not to provide his Personal Data, this might limit the processing of his Personal Data as set out in Article 4 below.
4 – Personal Data collection purpose
SEVES only collects Personal Data with the individual consent of a User. Personal Data is processed for the purposes listed below:
1. managing commercial relationship with customers, suppliers, business partners or any other third parties;
2. managing marketing and communication through newsletters or other communication actions related to SEVES Group activities;
3. managing Human Resources activities (e.g. recruitment).
5 – Storage conditions
All Personal Data collected are kept for a limited period depending on the purpose of the Personal Data processing and only for the duration provided for by the applicable legislation or defined by SEVES.
6 – Cookies
Cookies are text files stored on the device used by the User to visit our websites. Some cookies are essential for our websites to work, others collect anonymous or personal information to allow SEVES to improve our websites and to show the User relevant content.
Two types of cookies can be stored:
- Session cookies which are automatically deleted when the User closes his browser
- Persistent cookies which remain on the User computer/device until they are deleted or expired. Persistent cookies can keep the User preferences to help make future browsing easier and more relevant.
The User can manage cookie preferences through the browser settings. Some browsers allow the User to whitelist sites from which the User accept cookies. The User is always free to decline SEVES cookies if the browser permits, although in that case the User may not be able to use certain features on SEVES websites.
6.2 Types of cookies used by SEVES
Essential and functional cookies
Advertising and Marketing Cookies
- SEVES cookies
- Tracking cookies
Some of our websites banners may use tracking cookies. A tracking cookie will inform SEVES that the User has clicked on the banner and SEVES may use such information for commercial or statistical purposes.
SEVES may use anonymous statistical information to determine how many page views, visitors, location, and type of browser so that SEVES can better manage its websites infrastructures.
7 – Data transfer
SEVES may transfer Personal Data to third parties in the course of its activities or to provide a service. These transfers may be managed through the Internet, email, mail or any other method that SEVES deems appropriate and in accordance with the applicable legislation.
If SEVES becomes aware of the fact that a third party uses or discloses Personal Data without complying with this Policy or in violation of applicable law, SEVES will take all reasonable measures to prevent or remediate to such use or disclosure.
8 – Individual Rights and contact details
SEVES provides the Users the rights of access, rectification, erasure, portability and limitation of processing of such Personal data. Individual can express these rights by sending a postal letter or an email to SEVES Data Protection Responsible at one of the addresses below:
SEVES Group S.à r.l
Data Protection Responsible
10, rue Antoine Jans L-1820 Luxembourg
Users can also raise any questions about this Policy by contacting the SEVES Data Protection Responsible as per contact details mentioned hereabove.
9 – Security
SEVES is committed to avoid risks relating to confidentiality, integrity and availability impacting Personal Data.
As a consequence and in order to comply with privacy principles, SEVES, has implemented reasonable physical, logical and organizational security measures to prevent loss, unauthorized access or transfer, loss of availability and any alteration or destruction of such Personal Data.
10 – Conflict resolution
SEVES has taken reasonable organisational and technical measures to protect Personal Data.
However, if the User has reasons to believe that the security of his Personal Data has been compromised, the User can contact SEVES Data Protection Responsible as stated in Article 8 below.
SEVES will investigate claims and will take all necessary actions to resolve them in accordance with the principles set-up in this Policy.
The User may report privacy complaints directly to their local privacy supervisory authority.
11 –Revision of the Data Protection Policy
This Data Protection Policy may be updated as needed by SEVES or as required by law.