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PRIVACY STATEMENT of VTCS version 2.0

Name: VTCS

Address: Rue Beringerberg 1, 7410 Angelsberg, GD Luxembourg

VAT: LU34158301

As we comply with the GDPR/AVG – Legislation in force since 25/05/2018, we present to you this privacy statement.

Should there nevertheless be any questions after reading this statement, you can always contact our DPO at:

info@vtcs.lu

  1. WHAT:

In it we explain how we handle your personal data, what your rights are, how you can assert them, etc.

Terms used:

  • Personal data: by this the GDPR/AVG means any info that could identify a natural person, directly or indirectly. Further referred to as “data.” So it is NOT about corporate data!!!
  • Processing: collect, record, organize, structure, store, update or modify, retrieve, consult, use, transmit, distribute or otherwise make available, align or combine, block, erase or destroy personal data.
  1. WHICH:

We process the following personal data about you:

  • Name, address, phone number and/or cell phone number and e-mail address

This data came to us by:

  • That you yourself provided them to us during or prior to a personal interview.
  • By registering and logging into our website: https://www.vtcs.lu
  • To apply for jobs the resume, cover letter and degrees obtained.
  • Upon completion of an assignment, access will be provided to all systems in which personal data may have been stored. The DPO’s deontology is covered by professional secrecy. No copies of data are taken by the DPO.

We do not collect data by any other means.

3.GOAL:

We do this for the purpose of getting or staying in touch with you regarding services to be provided, following up on services provided, or responding to any questions you may have. This is a pre-contractual or contractual relationship.

Should we exceptionally receive other personal data from you privately, it will only be used for 1 well-defined purpose and kept only temporarily:

4.PROTECTION:

We will keep your data for as long as you use our Internet application and for as long as we need your personal data to provide you with a particular service.

Specifically:

  • Trading books: 7 years in original or electronic form with the retention period beginning January 1 of the year following the close of the fiscal year. Here we follow Article III.86 Code of Economic Law and article 9 of the R.D. of 12/09/1983 implementing the law of 17/07/1975 on the accounting of our company.
  • Justifying records: 7 years in original or electronic form with the retention period beginning that follows the close of the fiscal year. Here we follow Article II.86 Code of Economic Law.
  • Documents not serving as evidence against third parties: 3 years in original or copy where again Article III.86 of the Code of Economic Law applies.
  • Personnel records are kept for 5 years after leaving employment.
  • Resumes and Letters of Motivation 1 year.

5.SECURITY:

For this processing, we take the appropriate technical and organizational measures to optimally protect your data taking into account the nature of the data and the associated risks. We do not store any special personal data and have the following measures in place for the security of your data:

  • The computers on which data is processed are secured by default with a username and a complex password.
  • All computers are equipped with a Small Office Security solution which of course is always kept “up-to-date” and automatically performs multiple scans. All Windows installations are updated automatically. The installation is checked at least once a month and manually started if necessary.
  • The data is stored on a part of the disk set up as a “data vault.” This is encrypted and only accessible after booting up the computers + Windows login + opening a password vault.
  • To avoid data loss if the computers are lost, we make daily backups to an encrypted cloud environment and NAS Backup.
  • All passwords are managed and stored in the cloud environment.
  • Our employees are fully informed about the safe handling of your personal data and are bound by their employment contract to secrecy.
  • No records are kept on paper given the possibility of online registration and are not accessible to unauthorized persons.

Past experience tells us that no risk is completely avoided and should we become aware of unauthorized access to our IT systems or unlawful alteration, damage or possible loss of your data, we will immediately all necessary measures take steps to minimize and avoid this risk in the future. This will also keep the potential damage to you very limited.

  1. MARKETING PURPOSES.

CLICK BEHAVIOR AND VISIT DATA

General visit data is maintained on our company’s website. In this context, in particular the IP address of your computer, any username, the time of retrieval and data sent by a visitor’s browser may be recorded and used for statistical analysis of visit and click behavior on the website. We also optimize the operation of the website with this. We try to anonymize this data as much as possible. This data is never provided to third parties.

FACEBOOK, INSTAGRAM AND LINKEDIN

Our website includes buttons to promote or share pages on social networks Facebook, Instagram, Twitter and LinkedIn. These buttons are realized by code provided by the social media channels themselves. Among other things, this code sets a cookie (see above).

Please read the privacy statements of these social networks (which may change periodically) to see what they do with your personal data that they process using this code.

NEWSLETTER

We offer a newsletter through which we want to inform interested parties about news, our services and related matters. Your e-mail address will be added to the list of subscribers only with your explicit permission. Each newsletter contains a link that allows you to unsubscribe. The newsletter subscriber database is not provided to third parties.

CONTACT FORM

You want to fill out the contact form on our website? We normally use email to communicate with you

USE OF COOKIES

We use cookies when providing electronic services. A cookie is a simple small file sent with pages of this website and stored by your browser on your computer’s hard drive. We use cookies to remember your settings and preferences when you click to agree. According to privacy-by-design, analytic cookies are set to off by default. You can also disable these cookies through your browser.
For more information, please see our Cookie Statement.

  1. TRANSFER:

We provide your information to the following parties and for the purposes listed below;

  • The bookkeeper to meet our legal requirements of bookkeeping;
  • For employees: The social secretariat for the purpose of calculating wages;
  • The provider of this application for the purpose of ensuring the security and operation of this Internet application.

P.S. This is only your general personal data and will not be passed on to organizations and or individuals for marketing purposes.

For other parties, we do so only with your express consent or on your behalf.

We enter into processor agreements with the above parties that stipulate that they, too, must comply with GDPR/AVG guidelines.

At all times we will guard against your personal data being stored outside the EEA without a solid assurance from any relevant parties, that they too are fully compliant with GDPR/AVG legislation.

8.YOUR RIGHTS:

The following is a list of your rights regarding the processing of your personal data, whether they are/are applicable and how you can assert them:

  • Inspection: You have the right to request access to what data we hold about you and should there be any errors or omissions, request rectification, completion and even deletion. Art. 12-13-14
  • Right to rectification: Art. 15 You have the right to amend your personal data.
  • Attention!: If you request deletion this can only be carried out provided we no longer need your data for reasons other than those cited in our purpose description point 3.

Think especially about tax and social legislation.

  • Portability: If you wish to change service providers, we will transfer your personal data in a standard digitally readable format, to the new organization. Art. 19
  • Object to automated decision-making and profiling: Since we do not perform this, this is also not applicable.
  • Objection to data processing: This is only applicable if your data is used for direct marketing but since we do not perform this either this is therefore not applicable.
  • Right to transparency: You will be informed about the content of this privacy statement through this link, attached to every electronic contact and visibly posted in our offices.

A write-off can be provided to you upon simple request.

If you wish to assert 1 or more of these rights please request in writing with proof of your duplicate Opt-In verification by email and we will respond within 30 days.

  1. COMPLAINTS:

Should you disagree with the way we handle your personal data, respect your rights or this privacy statement, please let us know first so we can respond appropriately

You can always complain to the Data Protection Authority = GBA (the old Privacy Commission) at www.gegevensbeschermingsautoriteit.be at 1000 Brussels, Rue du Printing Press 35 or by mail to contact@apd-gba.be or by phone at 02/274.48.00

10.VARIA:

This updated privacy statement takes effect April 20, 2023.

We reserve the right to change this privacy statement at any time.

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