Welcome to ComparoLux and let us introduce what we do with your personal data.
New rules are running about privacy and personal data protection since the 25/05/2018.
So ,the purpose of this privacy notice (hereinafter "notice") aims to provide the information about how J2B Trust (hereinafter ” ComparoLux ”) ,acting as controller, collects, processes, shares and protects your personal data collected when you visit our website at www.comparolux.lu ( hereinafter the “Site”), in accordance with the General Data Protection Regulation ("GDPR") and the applicable national laws.
J2B Trust is committed to protect the privacy of everyone, and thus to comply with the laws and regulations on personal data come into force.
I. Who are we acting as Controller?
J2B Trust Sàrl, acting as controller, whose registered office is at 25, cite Morisacker, L- 7735, Colmar-Berg, Luxembourg.
Email : info@comparolux.com
R.C.S Luxembourg B238384 | Matricule TVA LU31618254 | Aut.ET 10096572/0
Our web applications are developed and hosted by
Jymbe Sàrl-S
18, rue des Prés
L-8147 Bridel
Luxembourg
Email : info@jymbe.com
II. Which personal data do we collect?
When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically collected information as “Device Information”. We collect Device Information using the following technologies:
- “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier.
For more information about cookies, please go to the section cookie policy and visit http://www.allaboutcookies.org - “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
- “Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the Site.
In order to communicate with us through the Site, including but not limited to the use of the Contact Form, we collect information, including name, email address, contact address and phone number. We refer to this information as “Contact Information”.
III. How do we use your personal information?
Our core business is providing the user with the best deals from partners through a matchmaking platform:
You are a user/requester
- You fill in a form with required information to refine your search and the contact form aforementioned
- A confirmation mail is sent to validate your enquiry
- Your request is then forwarded to our partners according to the criteria selected.
You are a user/partner
ComparoLux use or may use your personal data for the following purposes:
- To provide you with the matchmaking service to find the best deals (= connection with a supplier) - GDPR legal basis: consent and/or legitimate interest
- To share your information to our partners in order to provide you with a quote, a service or price offer (= results, request forwarding) - GDPR legal basis: performance of a contract with partner
- To deal with communications that you send to ComparoLux and responding to your queries, requests and complaints (= contact form) - GDPR legal basis: consent
- To carry out the recruitment process (= Job online) GDPR legal basis: consent or legitimate interest
- Promote events via pictures and videos disclosed on our social medias.
- To manage the infrastructure and business operations and to comply with internal policies and procedures - GDPR legal basis: legitimate interest, legal obligation
- To comply with any applicable laws and regulations related to our core business or to assist in law enforcement and investigations by relevant authorities - GDPR legal basis: legal obligation
IV. Sharing your personal information
Your personal data as part of the processing defined above may be transferred to partners:
ComparoLux shares your personal data as necessary to render any service you have requested or authorised namely for the following purposes:
- Matchmaking service: finding partner for single people or get a free quote
- Be a partner: propose service offers to users
- Recruitment: share a database whether you are applying or recruiting
ComparoLux may share your personal data with your consent for purposes like a subscription to a newsletter or invitation to an event.
I. Do we transfer any personal Data outside the European Union?
Your personal data as part of the processing defined above may be transferred to partners located within the European Union territory. Comparolux does not currently transfer personal data outside the European Union. However, Comparolux could be led to create partnerships with companies located in the UK, a country which will be considered as third party from 01/01/2021.
Our servers, hosted by Jymbe, are located in Amsterdam, Netherlands.
II. Your rights
Any data subject of which ComparoLux, as controller, processes personal data may exercise the following rights:
- Right of access: you have the right to obtain confirmation that we are processing your personal data and where this is the case to obtain a copy of these data;
- Right of rectification: you have the right to obtain from the controller without undue delay the rectification of inaccurate personal data that you concerned.
- Right to erasure: in specific cases, you have the right to request the erasure of your personal data. We may, however, retain certain information about you as required by law or when we have a legal basis to do so;
- Right to restriction of processing: you can the limitation of certain treatments carried out on your personal data. This right only plays in the following cases:
- When you dispute the accuracy of your data for the time needed to verify the accuracy of the data;
- In the case of unlawful processing by us and you do not wish the deletion of the personal data in question;
- We no longer need your personal data but these are necessary for the recognition, exercise or defense of rights in court;
- When you have exercised your right to oppose the time to verify that the legitimate reasons we are pursuing take precedence over yours;
- Right to object: you have the right to object at any time, on grounds related to your particular situation, to any processing of your personal data necessary for the performance of a task carried out in the public interest or based on legitimate interest;
- Right to data portability: you have the right to receive personal data that you have provided to us in a structured, commonly used and machine-readable format and to transmit these data to another controller. However, when the personal data are not processed by automated means, you do not fulfil the conditions to exercise your right to portability;
- Right to withdraw your consent: you can withdraw your consent at every moment when the processing activity is based on it;
- Right to lodge a complaint: you have the right to lodge a complaint with the competent supervisory authority: Use the online form available on the CNPD web site.
Commission nationale pour la protection des données
1, avenue du Rock’n’Roll
L-4361 Esch-sur-Alzette
All inquiries should be addressed to the address: info@comparolux.com
However, ComparoLux may refuse your request if it does not meet the requirements of applicable law or regulation.
III. Data retention
The GDPR introduces the principle of storage limitation of the personal data.
When you fill out the "Contact Form" in order to send us a message, we will maintain your Contact Information if necessary, for the purposes of the processing in question.
IV. Cookie policy
This Cookie Policy aims to provide information about the definition and uses of cookie through web application. ComparoLux is committed to protect the privacy of everyone, and thus to comply with the laws and regulations on personal data come into force, especially the E-privacy and its amendment
1. Web features management
a. Definitions
A cookie is “a text file that a Web browser stores on a user’s machine after the 1st visit. Websites activates cookies for authentication, storing website information/preferences, other browsing information and anything else that can help the Web browser while accessing Web servers. HTTP cookies are known by many different names, including browser cookies, Web cookies or HTTP cookies. ”
Session: it expires when the browser is closed
Permanent: it persists even when the browser is closed. They have an expiration date though and by law (e.g. remember passwords and login in order to not re-enter them every time).
Third-party: Cookies attributes usually corresponds to the website domain they are on. Not for third-party cookies as you probably gathered from the name, they are installed by third-party websites (no way), such as advertisers. They gather data about your browsing habits and allow them to track you across multiple websites. Other websites using third-party cookies like Facebook, Instagram, Google Analytics or LinkedIn.
Considering these definitions, ComparoLux shall use only the following ones:
| ajax.googleapis.com |
| www.google.com |
| code.jquery.com |
| www.facebook.com |
| www.google.com |
| connect.facebook.net |
| www.googletagmanager.com |
| connect.facebook.net |
| www.facebook.com |
| connect.facebook.net |
| cdnjs.cloudflare.com |
| www.gstatic.com |
| www.facebook.com |
| www.google.com |
| www.google-analytics.com |
b. Purposes of using Cookies
The cookies used on our website enable us to identify the pages a user visits, the resources he or she downloads and more generally their on-site visiting behavior.
- by offering personalized content and highlighting resources
- by adapting the interface to the device you are using (language, resolution, OS, etc)
- by memorizing information contained in forms you filled out on our site or via partner technologies* (sign-in to a real-life or virtual event, download of a resource, demo request, access to your Name's account)
- Cookies help collect statistical data regarding site frequentation and content consumption and enable us to offer an experience adapted to your needs and interests.
- We are using (e.g. Google Analytics) to measure our website's audiences.
- Offering targeted ads from our partners
- Optimizing the user experience on our site
- Improving our website
- Measuring our audiences
- Link to our social media
According to content consumed by the visitor on Comparolux website, cookies enable us to offer targeted ads regarding our content and services via our partners' retargeting service and receives on behalf of the client.
Examples of categories of such personal data can be found in the previous section.
c. Third-party cookies
Third-party cookies are deposited by other companies such as partners while you are surfing on our site or sharing personal data on our site using external services.
We are particularly vigilant as to the observance of partner websites of national data protection regulation and GDPR compliance and request that they take all appropriate measures regarding security and confidentiality of personal data.
Please find below the purpose of the cookies we are aware of and the means at your disposal to change cookie setup.
d. Third-party apps integrated into our website
We are using third-party apps on our web site in order to:
- to share our site's content with others (social sharing buttons): The corresponding social networks may be able to identify you via this button, even if you don't use it while browsing our site or app. If you opened a session on one of the networks on the device you use to visit our website before arriving on our site, the network can track your navigation on our site. We have no control over the collection of data by the social network regarding your navigation on our site and do not have access to personal data in their possession. However, you can access the confidentiality policy of the social network to learn more about the subject and regulate the information you agree or refuse to share.
- to collect your personal data (name, first name, email): We have no control over the quality of data management Google Analytics.
- To use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.
- to help us understand how our customers use the Site – you can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
- We also use a Facebook Pixel in order to improve our Facebook posts and/or ads. Facebook users can take control of their cookies here: https://facebook.com/policies/cookies.
- share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.
You can opt out of targeted advertising by:
- FACEBOOK – https://www.facebook.com/settings/?tab=ads
- GOOGLE – https://www.google.com/settings/ads/anonymous
- Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info. Or by visiting the European Interactive Digital Advertising Alliance at: http://www.youronlinechoices.eu.
e. Web tags and other technologies
We use web tags to track your navigation on our site and in our emails (via our marketing automation solution). Web tags are code lines that recognize given types of information on your computer, such as cookies, time and date of a page visit, or description of the page where the tag is located.
We use this type of tags to improve the navigation experience on our site and to understand if user read and click our emails, with the aim to offer users’ content consistent with their expectations.
f. Mobile device
Certain mobile devices send information regarding the model of the phone the OS version, the connectivity, the name and version of used apps or the geographical location at the time of the connection.
This data is automatically processed by Google Analytics and Facebook. This enables us to offer relevant experiences, in line with the technical characteristics of your device.
g. Accept or refuse Cookies
You can choose not to receive cookies from our website at any time. You can decide to block cookies we may deposit in your navigator, either case by case or by refusing them systematically once and for all.
Note that if you refuse our cookies, we cannot guarantee an optimized browsing experience.
For an efficient cookie management meeting your requirements please use your browser's setup options, considering the cookies' purpose (as mentioned above).
You can also delete cookies already stored in your browser. For instance, to delete cookies deposited by ComparoLux website:
Google Chrome
Open the browser's "Settings" tab. Click on "Advanced" followed by "Privacy and security", "Content settings», then "cookies" and "See all cookies and site data". Search "[Name]", tick the boxes and delete.
Firefox
Open the browser's "Options" tab and select "Privacy and Security". In the "History" section, click on "remove individual cookies". Search files containing the name "[Name]", select and delete them.
Microsoft Edge
Click on the "Other action", then on "Settings" ». Click on " Choose data to delete". Check the box "Cookies data from registered websites", search files containing "[Name]", select and delete them.
Safari
Open, the browser's "Preferences" tab and open the tab "Confidentiality". Click on "Manage website data”, search files containing "[Name]" select and delete them. Click on "Done".
If you have any questions or concerns about our use of your information or regarding our Cookie Policy, you may contact us by sending an email to info@comparolux.com
2. Web analysis by Google Analytics
This website uses the “Google Analytics” services, offered by Google Inc. (1600 Amphitheatre Parkway Mountain View, CA 94043, USA), to analyse the users‘ website experience. This service uses “cookies“ – text files, which will be saved on your device. The information collected via these cookies is typically sent and saved to one of the Google servers in the US and Worldwide.
According to the recent CJEU's judgement and the GDPR rules, the set of operations shall be covered by another appropriate safeguard such a contractual clause in the agreement between Comparolux and the service provider or derogation for specific situations listed in art 49.
This website is subject to IP anonymisation. Inside the EU and the European Economic Area, the respective user’s IP address will be abridged. This process eliminates any personal connection of the IP address to the user. In connection with the agreement on contracted data processing entered by and between the website operator and Google Inc., the latter will use the collected information to provide the former with an evaluation of the users‘ website experience and the website performance and to provide services related to internet use.
You may prevent cookies from being saved to your system by changing the corresponding settings in your browser. Should your browser not accept cookies, we cannot guarantee that you may use all functions of this website without constraints.
Furthermore, you may use a browser plug-in to prevent that the data collected by the cookies (including your IP address) will be sent to and used by Google Inc. The following link will lead you to the corresponding plug-in: https://tools.google.com/dlpage/gaoptout?hl=de
As an alternative to the browser add-on or with browsers on mobile devices, please click on this link to prevent Google Analytics from future data collection on this website (the opt-out will only apply to this browser and to the present domain. Clicking the provided link will save an opt-out cookie to your device. Should you delete the cookies saved to your browser, you will have to click the provided link again to enable the opt-out anew.
3. How do we make your personal data secure?
We shall implement, test and maintain the appropriate organisational, physical and technical security measures (including with respect to personnel, facilities, hardware and software, storage and networks, access controls, monitoring and logging, vulnerability and breach detection, incident response, encryption of personal data) to protect against unauthorised or accidental access, loss, alteration, disclosure or destruction of personal data.
4. What about data breach?
ComparoLux shall communicate to its customer of any personal data breach by ComparoLux, its processors, or any other third parties acting on ComparoLux behalf without undue delay, only where the personal data breach is likely to result in a high risk to the rights and freedoms of the client.
5. Changes
We may update this privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons.
6. Contact information
For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at info@comparolux.com
Last updated: June 26, 2020 © 2020 ComparoLux