Respect for privacy and use of personal data
e-lma, company located at 23-25 Route de Luxembourg, L-3253 Bettembourg – Luxembourg (hereinafter the “Provider”) is the author of this Privacy Policy.
For the sake of simplicity, all persons affected by the data processing are hereinafter referred to as “User(s)”
The privacy and the security of personal information is important to us. e-lma strongly believes that the Users have the right to control the use of personal data, and that their privacy must be respected.
This Privacy Policy applies to all Users of the Provider’s services, insofar as personal data is processed in connection with the delivery of these services.
e-lma is committed to safeguarding the privacy of its clients and website visitors. This policy sets out how we collect and treat Users personal information.
e-lma only collects and uses Users personal information in case of legitimate reason for doing so.
This Privacy Policy was last updated on August 28, 2022. However, the Privacy Policy can change over time, for example to comply with legal requirements or to meet changing business needs.
What personal information is collected
The following e-lma privacy policies are tailored for the different ways Users Personal Information may be collected, used, shared and processed by different e-lma’s lines of business.
“Personal Information” is information e-lma holds which is identifiable as being about the User. This could include among other things the name, email address, identification number, or any other type of information gathered through Users interactions with e-lma that can reasonably identify an individual, either directly or indirectly.
How we collect Users personal information
e-lma collects personal information from the users in a variety of ways :
- When they interact electronically or in person
- When the user accesses e-lma’s website
- When they engage in business activities together
e-lma may receive personal information from third parties. If so, e-lma will protect it as set out in this Privacy Policy.
By providing e-lma with personal information, Users consent to the supply of that information subject to the terms of this Privacy Policy.
Non-personal information collected automatically
When the Users access our website, e-lma may automatically (i.e., not by registration) collect information that is not personally-identifiable (e.g : type of Internet browser and computer operating system used; domain name of the website from which users came; number of visits, average time spent, pages viewed).
e-lma may use and share this information with its worldwide affiliates to measure the use of its website and improve the content
How e-lma uses personal information about the Users
We may use personal information of the Users for the following purposes:
- to analyze, develop, improve and optimize the use, function and performance of our websites, products and services;
- to manage the security and operation of e-lma websites, facilities, and networks and systems;
- to comply with applicable laws and regulations and to operate e-lma’s business.
- to communicate and respond to Users requests and inquiries to e-lma;
- to provide Users with information about e-lma’s products and services;
- to communicate with the Users by a variety of measures including, but not limited to, by telephone, email, sms or mail;
- to administer subscriptions of e-lma’s publications and newsletters;
- to market e-lma’s products and services or related products and services, and to tailor marketing and sales activities to Users interests;
Contact information such as Users email address or phone number collected online or offline from interactions between e-lma and the Users and used for direct marketing and sales activities, will be retained for as long as e-lma has an active (customer) relationship with the Users.
Users are considered as an active contact if they have interacted with e-lma or updated their contact details and preferences and have not made a deletion request.
e-lma may also use Users personal information to investigate any complaints. If Users withhold their personal data, they may not be able to fully access e-lma’s website or products and services. E-lma may be compelled to disclose Users personal information to comply with any legal requirement, such as a law, regulation, court order, legal proceedings, etc or in response to a request from a law enforcement agency.
e-lma reserves the right to transfer – to the extent permissible at law – the User’s database, and any personal and non-personal information contained in those databases in case there is a change in e-lma’s business (e.g : change of control of the company, sale or transfer of business assets).
Disclosure of the User’s personal information
e-lma may disclose the User’s personal information to any of e-lma employees, managers, partners (insurers, professional advisers, agents, suppliers or subcontractors etc) as reasonably necessary for the purposes set out in this Privacy Policy.
In the case e-lma discloses the User’s personal information to a third party, e-lma remains committed to protect it in accordance with this privacy policy.
General Data Protection Regulation (GDPR) for the European Union (EU)
e-lma is committed to respecting the principles of data protection stated in the GDPR for the purposes of fairness, transparency and the lawful collection and use of data.
e-lma processes the Users personal information as a Processor and/or to the extent that e-lma is a Controller as defined in the GDPR.
It is imperative to establish a lawful basis for processing the Users personal data. The legal basis for which e-lma collects the Users personal information depends on the data that e-lma collects and how it is being used.
e-lma will only collect Users personal information with their express consent for a specific purpose and any data collected will be to the extent necessary and not excessive for its purpose. E-lma will keep the Users data safe and secure.
e-lma will also process Users personal information in case it is necessary for its legitimate interests, or in order to fulfil a contractual or legal obligation.
e-lma will process Users personal information in case the user’s life needs necessarily to be protected or if the User is in a medical situation, it is necessary to carry out a public function, a task of public interest or if the function has a clear basis in law.
E-lma does not collect or process any of the Users personal information that is designed “Sensitive” under the GDPR, such as sensitive personal information relating to the User’s sexual orientation or ethnic origin unless e-lma has obtained an explicit consent from the User, or if it is being collected subject to and in accordance with the
GDPR.
Users must not provide e-lma with personal information if they are minor without a parental consent or the consent of someone who has parental authority for them. E-lma does not knowingly collect or process the personal information of children.
Data Sharing with Third Parties/Trustees
The User has the possibility of sharing his data with third parties, in particular his personal trustee, directly or within the framework of the partnership program developed by e-lma. By granting access rights, the User accepts that e-lma makes all its data available to a third party (the fiduciary, for example) or allows access to it. The
User retains full control of third party access rights to his data at all times and may restrict or deny such access at any time. However, e-lma reserves the right to disclose specific data to authorized third parties in justified individual cases.
Users rights under the GDPR
Individuals residing in the EU have certain rights as to how their personal information is obtained and used.
- The right to be informed about how their personal information is being used;
- The right to access their personal information;
- The right to correct their personal information if it is incorrect or incomplete;
- The right to delete their personal information (also known as “the right to be forgotten”);
- The right to limit processing of their personal data;
- The right to keep and reuse their personal information for their own purposes;
- The right to object to their personal information being used;
- The right to object against automated decision making and profiling.
Access to personal information
Users have the right to request the details about the personal data held about them in e-lma’s system. If the users wish to receive a copy of their information or believe that any information e-lma holds on them needs to be updated, modified or corrected, elma remains at disposal to deal with the Users requests via the “Contact Us” section.
However, e-lma reserves the right to refuse to provide the Users with information that they hold about them, in certain circumstances set out in the Privacy Act or any other applicable law.
Links to Other Web Sites
e-lma website may contain hyperlinks that refer to third websites which are not operated or controlled by him. E-lma cannot be held responsible for their content or their data protection practices.
“Cookies”
Cookies make the visit to the Supplier’s website easier, more pleasant and more relevant.
Cookies are files containing information that the web browser automatically saves on the computer’s hard drive when the User visits the website. So when the User is on e-lma’s website, e-lma may store some information on his computer in the form of a “Cookie” to automatically recognize him the next time he visits.
Cookies can help in many ways, for example, by allowing e-lma to tailor its website to better match the User’s interests or to save his password so that he does not have to re-enter it each time.
The User has the possibility of modifying the security parameters of his browser in order to block or desactivate cookies. However, it is then possible that certain services can no longer be used in their entirety.
If the User choose not to be recognized, it is important to ask his Internet browser to erase Cookies from his computer hard drive, block all Cookies or receive a warning before a Cookie is stored.
Security
Protecting the security and privacy of the Users personal information is important.
e-lma takes the necessary security measures in accordance with the required standards to protect the personal data it collects against control, deletion, alteration, access, transmission or other unauthorized use and avoid any partial or complete loss of this data.
e-lma declines all responsibility in case of loss of data or consultation and use of data by third parties. e-lma is not able to guarantee the security of data transmissions over the Internet. The transmission of data by e-mail notably involves a risk of intrusion by third parties. However, access is protected using the HTTPS protocol.
e-lma hopes that the policy outlined in this page will help to understand what information is collected, how it is used and protected but also with whom it may be exceptionally shared and in which conditions and for which purposes.
Complaints about privacy
If the User have any complaints about e-lma’s privacy practices, or considers that the processing of his personal data do not respect the GDPR regulations, he may contact e-lma via the “Contact Us” section.
e-lma takes complaints very seriously and will react shortly after receiving written notice of the User’s complaint
Contact
In case the Users have any questions or comments about e-lma Data Privacy Protection Policy, e-lma is available via the section “Contact Us”.