DATA PROTECTION POLICY
1. Our commitment
The protection of personal data is a key priority for Caelis S.à.r.l. which, acting as the Data Controller, takes the necessary steps to ensure that your personal data is processed in accordance with the RGPD - General Data Protection Regulation.
We will always use your personal data in a fair and trustworthy manner and take all reasonable steps to protect your information from misuse and to keep it secure.
You have the right to be clearly informed about how we use your personal data and to request its correction or deletion. We will always be transparent with you about what data we collect and how we use it.
We comply with all applicable data protection regulations and cooperate with the CNPD - Commission Nationale pour la Protection des Données, the Luxembourg supervisory authority for data protection.
What does this document cover?
It covers Caelis S.à.r.l.'s rules of conduct on privacy, which set out the types of personal data we collect, and how we use, disclose and protect them.
How to change these rules
We may change these privacy policies by publishing an updated version of these policies. We will give you notice of any changes.
2. Rules of conduct
In these privacy rules of conduct, your “personal data” means one or more pieces of information that could directly or indirectly identify you. This generally includes information such as your name, address, identifiers, photos/videos, e-mail address, and telephone number, but may also include other information about your past or present professional activities, employee health and safety data.
In the course of our activities, we may collect different types of personal data depending on the categories of people concerned.
Personnel:
Personal data.
Data relating to professional life.
Recruitment data.
Economic and financial information.
Connection data.
Users of the https://www.caelisimmo.com website:
- Identification data.
- Connection data.
- Internet activity data.
- Data from surveys, forms and newsletter subscriptions.
How do we collect your personal data?
We may collect this from a number of sources:
- Information you give us directly.
- Information we may collect via our partners.
- Information from state bodies.
How do we use your personal data?
We use your personal data as part of the overall management of our business:
To provide you with service offers;
To process the service contracts we have concluded with you;
To manage the delivery, billing and payment of our services;
Process your invoices for accounting purposes;
Establish a customer database;
Fulfill legal obligations in professional, social, accounting and tax matters;
Fulfill contractual obligations of the employment contract;
Organize the day-to-day management of work within the company, without any individual profiling.
How long do we keep your personal data?
Where we collect personal data for these purposes only, we do not keep it for longer than is necessary to fulfil that purpose, unless legitimate legal or contractual reasons require a longer storage.
Purposes and legal basis for processing
Contract management
Caelis S.à.r.l. processes personal data for the purposes of drawing up, managing and monitoring contracts with:
- employees: employment contracts, collaboration agreements;
- third parties: commercial contracts, service contracts.
The legal basis for such processing is the execution of a contract or pre-contractual measures, insofar as such processing is necessary to respond to requests received, or to set up or execute the contract in question.
Compliance with legal obligations
Caelis S.à.r.l. processes personal data as part of its mobility, relocation and immigration advisory activities.
The legal basis for such processing is the fulfilment of the following legal obligations: Social, accounting and tax obligations, i.e. affiliation, KYC, anti-money laundering procedures, etc.
The pursuit of legitimate interests
Caelis S.à.r.l. processes personal data in order to organize and optimize its services. Examples of such processing are mentioned (but not limited to) here below:
- Management of personnel, training and remuneration.
- Travel organization.
- Sales, accounting, IT and logistics.
- Marketing, communication, digital development.
- Customer satisfaction surveys.
The legal basis for such processing is the pursuit of legitimate interests or the safeguarding of vital interests of the data subject or another natural person.
Managing requests
Caelis S.à.r.l processes your personal data for the purposes of :
- Managing requests from users of the https://www.caelisimmo.com website
- Processing requests via forms, newsletter registration, cookie management.
- Marketing, communication or profiling operations.
- The legal basis for this processing is your consent, which you may withdraw at any time.
Implementation of your consent
When personal data is collected that does not result from a legal or contractual obligation, Caelis S.à.r.l. informs you that its transmission is optional and implies, as soon as it is transmitted, consent to its subsequent computerized processing in compliance with the present conditions.
With whom do we share your personal data?
At Caelis S.à. r.l., we do not share your personal data as a general principle. However, in the context of managing your personal file, salaries, social security contributions, travel details, we do share your data with carefully selected and controlled subcontractors or partners.
We may also share your personal data with organizations if we believe that disclosure of the information is necessary for legal reasons in connection with legal proceedings.
Do we transfer your personal data to other countries?
We do not transfer any of your personal data to servers outside the European Union (EU) and we use subcontractors who undertake to keep your data within the EU.
Where personal data that is the subject of these rules of conduct is transferred (including in the case of remote access) to countries outside the EU that do not benefit from an adequacy decision of the European Commission adopted in accordance with Article 25 of Directive 95/46/EC or Art. 45 of the RGPD, Caelis S.à.r.l. ensures that appropriate safeguards as provided for in Chapter V of the RGPD are put in place.
How do we protect your personal data?
We take all reasonable precautions to keep your personal data secure and we require any third party who handles or processes your personal data for us to do so.
If Caelis S.à.r.l. collaborates with other companies, the choice of these companies will only be made after a complete selection process. In this selection process, each individual service provider is carefully selected for its suitability in terms of technical and organizational data protection so it complies with identified security requirements, including European and national regulatory requirements.
3. Specific use of your personal data
Cookies
Cookies are used by Caelis S.à.r.l. to analyze the use of our website in anonymous or pseudonymized form and to offer the user advanced functionalities. You can consent to the type of cookies authorized, apart from those strictly necessary for the proper functioning of the site. The types of cookies and their purposes can be consulted at the time of consent. You can of course withdraw or change your consent at any time.
Use of your data for information and advertising purposes
In addition to providing our services, we also use your personal data to communicate with you about our marketing offers or promotions and to recommend other services that may be of interest to you.
What are your rights and how to exercise them?
If you have any questions, comments or concerns about the way we handle your personal data, you can contact the Data Protection Officer by e-mail (dpo@caelisimmo.com) or by post: Caelis S.à.r.l, 15 Am Laangert L-4971 Dippach
You have the right to :
- Request a copy of the personal data we hold about you.
- Ask us to correct, update or delete your personal data from our files.
- Notify us of any misuse of your personal data.
If you feel that your personal data has not been processed in accordance with the law, you can complain before the CNPD (www.cnpd.lu or databreach@cnpd.lu).