Data protection
Foreword
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Digital Inclusion (hereinafter referred to as « Digital Inclusion ») attaches great importance to your privacy and is aware of the importance you attach to it.
Digital Inclusion therefore endeavours to ensure that you can use the services offered on this website with confidence, in particular by processing your data transparently, in strict compliance with applicable data protection laws and regulations and in accordance with your own preferences.
Person responsible for processing your personal data
Any personal data collected from this website is processed automatically by :
Digital Inclusion
Address : 41 rue Charles IV L-1309 Luxembourg
When is your personal data collected ?
In the course of using this website, Digital Inclusion may collect your personal data at various points or times when :
- you browse the pages of the website,
- you subscribe to our information feeds (Newsletter, flux RSS, notifications, etc.),
- you contact us (« Contact » section),
Digital Inclusion takes care to collect only the data that is strictly necessary for the provision of the services you wish to use.
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Purposes of processing your personal data (« Purposes »)
Your personal data collected by this website is processed electronically for the following purposes:
- To provide you with the service or information requested
- To compile statistics and analyses of visitor numbers, in order to improve the quality of the services offered
- To inform you about products, events, services & offers from Digital Inclusion and its partners if you have subscribed to these information feeds (Newsletter, flux RSS, etc.),
- To enable you to benefit from personalised commercial offers or advantages, as part of our loyalty programme, if you have subscribed to it
- To send you advertising or commercial prospecting messages, provided that you have given your consent
- Ensure the security of access to your personal data, and detect any attempts at computer intrusion
- To manage your opinions via surveys in which you participate
- To offer you the opportunity to take part in contests or lottery
For each of the purposes listed above, the processing of your personal data is legally based on :
- the fact that it is necessary for th perfomance of a contract between Digital Inclusion and you, or for the performance of pre-contractual measures taken at your request ;
- the fact that it is necessary to comply with a legal obligation to which Digital Inclusion is subject ;
- the basis that you have given your consent to the processing ;
- the basis of an interest recognised as legitimate by Digital Inclusion (fraud prevention, data and infrastructure security, etc.).
Digital Inclusion will ensure that your personal data is processed in a manner that is fully compatible with the purposes set out above. If your data is to be processed for a purpose other than that for which it was originally collected, you will be given all the necessary information beforehand. You will then be given the opportunity to object to this further processing.
Nature of personal data collected
Your «personal data » refers to all information concerning you as an individual and which makes it possible to identify you, directly or indirectly.
The personal data that Digital Inclusion may collect when you browse this website is :
- basic identification data, such as your first and last names, postal address, e-mail address, telephone numbers, etc.
- technical connection and browsing data, such as the IP address of your terminal, the date and time of your connection, the pages visited, the characteristics of your browser (type, language, etc.) and your terminal (type, resolution, etc.) cookies, etc.
- geographical location data (geolocation),
- publication data, such as your centres of interest, opinions, comments, notes, messages published via the forums and the site's community and social functions.
Some of the information collected is compulsory in order to achieve the objectives described above, while other information is optional. You are systematically informed on the compulsory or optional nature of the information at the time it is collected. If you do not complete certain mandatory fields, thi may result in Digital Inclusion being unable to provide you with the product or service concerned, or to guarantee you the expected quality.
Recipients of your personal data
The personal data collected about you on this website is intended solely for the use of Digital Inclusion. It may, however, be passed on :
- to sub-contractors used by Digital Inclusion to provide services, such as hosting and operating the website, sending our newsletter, and managing, processing and paying for your online purchases.
- to commercial partners, provided that you have given your consent to receive solicitations from them.
Finally, Digital Inclusion may be obliged to pass on your personal data to a third party at the request of the judicial authorities or any administrative authority authorised by law.
Your personal data will not be passed on to any other third party.
Digital Inclusion also ensures that any transfer of your personal data to authorized third parties does not result in a transfer to a third country outside the European Union.
How long we keep your personal data
Your personal data collected and processed by Digital Inclusion will only be retained for as long as is strictly necessary for the purposes for which it is to be processed or in order to comply with a legal obligation imposed by applicable law. Digital Inclusion will therefore retain :
- a maximum of 3 years from the end of the commercial relationship for data processed for the purposes of commercial canvassing, marketing actions and/or promotion of the offers of Digital Inclusion and its partners
- a maximum of 10 years from the end of the commercial relationship for data relating to contractual aspects (contracts, claims, recovery & litigation, etc.) or accounting aspects (invoices, order forms, delivery notes, etc.)
Protection of your personal data
Digital Inclusion implements security measures that are appropriate and reasonable in the light of the risks presented by the processing,in order to protect your personal data against destruction, loss, alteration, unauthorised disclosure or access and any other form of unlawful processing.
All Digital Inclusion employees and sub-contractors who have access to your personal data are bound by strict professional confidentiality. They only access the data they need to do their job and are regularly made aware of, or trained in, the compliance and security rules that apply to your personal data.
Your rights
Insofar as Digital Inclusion processes your personal data, you have the following rights at all times and within the limits set by law:
- to access your personal data (to find out what data has been collected and processed and to obtain a copy of it), to ask for it to be rectified if it is inaccurate or incomplete, or to be deleted if it is obsolete;
- object to the processing of your data on legitimate grounds (in particular for commercial canvassing purposes);
- if the preconditions are met, request that the processing of your data be restricted or that it be permanently deleted (right to be forgotten);
- ask to receive a copy of the personal data you have provided to Digital Inclusion in a structured format (portability), unless this right infringes the rights and freedoms of third parties;
- ask not to be subject to a decision based exclusively on automated processing, including profiling, where that decision produces legal effects concerning you or significantly affecting you in a similar way. You may also request information about the logic behind such processing, challenge it and request that it be reviewed by a natural person.
-withdraw your consent at any time for processing ooperations based on your consent.
You may exercise any of these rights free of charge by contacting us :
- by e-mail to the following address : info@digital-inclusion.lu
- or by post addressed to: 41 rue Charles IV L-1309 Luxembourg
In order for us to be able to satisfy your request and to avoid any identity theft, a copy of both sides of a valid identity document must be attached to your letter.
Digital Inclusion undertakes to respond within a maximum of one month following receipt of your duly completed request.
You can also lodge a complaint with the Commission Nationale pour la Protection des Données (CNPD), via their website : www.cnpd.lu