Data Protection Notice | skeeled.com

Personal Data Protection Notice to Vendors, Customers, Web Users

Introduction

Skeeled S.à r.l. (hereinafter "Skeeled", "company", "we", “us” or “our”) attaches great importance to the protection of personal data and undertakes to comply with Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 ("GDPR") as well as any other applicable laws and regulations.

Scope

This Data Protection Notice (“Notice”) explains how Skeeled collects, uses, shares and otherwise processes your personal data in connection with your relationship with us as a supplier, partner, visitor, customer or acting for a customer or being generally interested in our services, in accordance with applicable data protection laws and regulations.

Update

This Notice will be reviewed on a periodic basis. Any changes to this Notice shall be approved by Skeeled. The latest version of this Notice will always be available on our website.

Categories of personal data processed

The term “personal data” means any information that relates to you and allows us to identify you, either directly or in combination with other information that we may hold.
We may collect personal information from you in the course of our business, including through your use of our website and software, when you contact or request information from us, when you engage our services and create a user account or as a result of your relationship with one or more of our consultants or customers or when you visit our premises.

Thus, the information we collect may include your name, gender, age range, contact details, job title, username, password, communication data and any other personal data you may provide in the course of your pre-contractual, contractual and commercial relationship with Skeeled that we can also collect from publicly available sources.

In addition, we collect your data when you contact us directly through any communication channel (e.g., when you send us an e-mail containing a comment or a feedback) including your name, address, telephone number, e-mail address and any other information you may send to us.

Some of your information is collected automatically. Thus, when you access our website, we may automatically collect, through log files, certain information from your device, such as the IP address, the operating system of your device, the pages visited, the requests made, the day and time of connection and the information associated to your account such as your username, e-mail address and password. The use of such files allows us to offer you a more consistent experience on the website.

During your visit, a banner appears at the bottom of the screen informing you of the use of cookies when browsing the website. A cookie is a small piece of data or message that is sent from an organisation's web server to your web browser and is then stored on the hard drive of your device (computer, tablet, mobile, etc.). Some cookies do not collect any personal data but simply ensure smooth and optimal navigation on our website. It is up to you to make a choice between accepting or refusing the use of optional cookies depending on the services proposed. To learn more about the types of cookies and similar technologies we use and how you can control these technologies, please see our Cookie Notice.

Legal bases and purposes of processing

We always process your personal data for a specific purpose and only process the personal data which is relevant to achieve that purpose.

We will only use your personal data for the purposes for which we collected it and which we informed you about, unless we reasonably consider that we need to use it for another reason which is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Recipients of personal data

We may use or disclose personal data if we are required by law to do so or if we reasonably believe that use or disclosure is necessary to protect our rights and/or to comply with judicial or regulatory proceedings, a court order or other legal process.

To achieve the purposes mentioned above, the data is transmitted to the following recipients:

Internal employees who have permission;
Network, technology systems and IT service providers acting as processors and on instruction from Skeeled.

Any relationship with a processor is managed in accordance with the provisions of Article 28 of the GDPR. Skeeled only uses data processors that provide sufficient guarantees and abide by the same obligations.

Some of the above-mentioned recipients may be based in third countries. Where this is the case, transfers will be undertaken in line with Chapter V of the GDPR and applicable data protection laws and regulations. Where a third-party service providers process personal data outside the EEA in the course of providing services to us, our written agreement with them will include appropriate measures, usually in the form of standard contractual clauses.

Personal data retention period

Your personal data is stored by Skeeled only for as long as is necessary for the purpose for which we obtained them.

Thus, the log files collected during interactions with the website are destroyed after 6 months after the moment of the collection.

Furthermore, the personal data we collect when responding to your requests will not be kept for more than 3 years from the last contact with Skeeled if no contact is signed between you and Skeeled.

We may also keep and process your personal data after the termination of our contractual or commercial relationship for specific purposes such as the compliance with other legal obligations (as a rule, data must be kept for a period of 10 years for commercial matters) or the establishment, exercise, or defence of legal claims.

Upon expiry of the applicable retention period, we will securely destroy your personal data in accordance with applicable laws and regulations.

Security of personal data

We implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk so that the processing complies with the GDPR and applicable date protection laws.

These measures must provide for a level of security considered appropriate considering the technical standards and the type of personal data processed but also:

the state of the art and implementation costs.
the nature, scope, context, and purposes of processing; and
the likelihood and severity of the risk to the rights and freedoms of natural persons.

Security requirements are continually evolving, and effective security requires frequent assessment and regular improvement of outdated security measures. We are committed to continuously evaluate, strengthen, and improve the measures we implement.

Data subjects’ rights

As a natural person, you have several rights regarding your personal data that we can exercise in certain circumstances, including:

the right of access: You can request access to the data concerning you at any time as well as a copy of the data.
the right to rectification: You can request at any time that inaccurate or incomplete data be rectified.
the right to erasure: You can request that your data be deleted when, for example, the data is no longer necessary for the purposes for which it was collected or processed.
the right to restriction of processing: You can request that Skeeled restrict the processing of data if, for example, you question the accuracy of the data concerning you or if you object to the processing of data concerning you.
the right to data portability: You have the right to have your data transferred to another data controller in a structured, commonly used, and machine-readable format, if the processing is carried out by automated means or if it is based on prior consent.
the right to object to processing: You can object to the processing of your data and can withdraw your consent if the processing is based on consent, for example if the data is used for commercial prospecting purposes.

If you wish to exercise your rights, please contact us at dpo@skeeled.com

Your request will be responded to within 1 month at the latest, starting from the moment of your identity confirmation. We may extend the time limit by a further 2 months if the request is complex or if we have received a high number of requests.

You will in general not have to pay a fee to exercise any of your individual rights mentioned in this Privacy Notice. However, we may charge a reasonable fee if your request to exercise your individual rights is manifestly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

If you are not satisfied with our response, you also have the right to lodge a complaint at any time with the National Commission for Data Protection (CNPD): https://cnpd.public.lu/

Links

Our website contains links to other websites but note that this Notice applies only to personal data collected by Skeeled and to how Skeeled processes personal data. We are not responsible for the privacy practices of other websites.