Privacy Policy
FINANCIERE LX S.A. (the Company or we), attaches great importance to the protection of personal data and privacy of visitors and users (Users or you) of the website www.Fondamentalgroup.com (the Website).
We undertake to process your personal data in accordance with the legislation applicable to the processing of personal data and, in particular, European Regulation No. 2016-679 of 27 April 2016 (the GDPR) and the Luxembourg law of 1 August 2018 on the organization of the National Commission for Data Protection and implementation of the GDPR (together the Legislation).
The purpose of this policy (the Policy) is to inform you about how we, as a data controller (as this term is defined in the GDPR), use your data as well as the rights you have when you visit our Website or interact with us via the contact form or apply for a job or internship via our recruitment page.
This Policy is intended to apply only to the processing of any information relating to an identified or identifiable natural person (Personal Data).
DATA CONTROLLER
FINANCIERE LX S.A., 43-45 rue Glesener L-1631 Luxembourg.
WHAT DATA DO WE COLLECT?
When you browse our Website, we automatically collect certain information of a technical nature, the transmission of which is an integral part of Internet communication protocols. This information is not collected to be associated with you but, by its very nature, it can identify you by processing it and associating it with data held by third parties. Among the Personal Data collected, such as the device used, the IP address, the date and time of navigation (timestamp), the type and version of the browser, the operating system used, the pages you have consulted, your language preferences.. For more information on the use of cookies see point USE OF COOKIES below.
When you interact with us by completing the contact form, we process the data you provide voluntarily to us, namely your identification data (surname, first name) and contact data, namely your surname, first name and (e-mail address), the reason for your contact, the content of your communication, as well as the technical details of the communication itself (including date and time.).
When you apply for a position or internship, we process the data you provide voluntarily to us, i.e. your identification and contact data (surname, first name, e-mail address) and the position referred to via the form, as well as the data included in your curriculum vitae and a cover letter (including education, professional experience).
Some information marked with an asterisk must be filled in. Otherwise, our ability to manage your requests may be impacted.
FOR WHAT PURPOSES DO WE COLLECT YOUR PERSONAL DATA AND ON WHAT LEGAL GROUNDS?
We collect and process your Personal Data for the following purposes and legal grounds:
PURPOSE
Management of requests for information and/or comments that you send to us LEGAL GROUND Performance of contractual or pre-contractual measures taken at your request
Legitimate interest
PURPOSE
Management of applications for job or internship offers published on the Site or spontaneous applications made via the Website
LEGAL GROUND
Performance of pre-contractual measures taken at your request
Legitimate interest
PURPOSE
Creation of a CV library or development of a "pool of applications" database
LEGAL GROUND
Consent
PURPOSE
Communication of applications to the companies of the Groupe Fondamental* to which the Company belongs
LEGAL GROUND Consent
PURPOSE Operation and security of the Site, improvement of the user experience**
LEGAL GROUND Legitimate interest
PURPOSE
Management, measurement and monitoring of the audience of its website**
LEGAL GROUND Consent
Legitimate interest
* "Groupe Fondamental" means companies whose control is directly or indirectly held by Mr. Denis Dumont and/or Mr. Florent Rey.
** For more information on the use of cookies see point 8 USE OF COOKIES below.
WHAT ARE YOUR RIGHTS OVER YOUR PERSONAL DATA?
In accordance with the Legislation, you have the following rights:
- The right to be informed. You have the right to obtain concise, transparent, intelligible and easily accessible form, using clear and plain language about how we use your Personal Data and your rights. This is the purpose of this Policy.
- The right of access. You have the right to access your Personal Data.
- The right to rectification. You have the right to request that your Personal Data be rectified if it is inaccurate or out of date and/or be completed if it is incomplete.
- The right to erasure/right to be forgotten. In some cases, you have the right to obtain erasure or deletion of your Personal Data. This is not an absolute right, as we may be required to retain your Personal Data for legal or legitimate reasons.
- The right to restriction of processing. You have the right to request the restriction of the processing we carry out on your Personal Data. This right means that our processing of your Personal Data is restricted, so we may retain that data, but not use it. This right applies in special circumstances provided for by the GDPR.
- The right to withdraw consent. You may withdraw your consent to the processing of your Personal Data if such processing is based on consent. The withdrawal is only valid for the future and will not affect the lawfulness of the processing carried out before this withdrawal.
- The right to object. You may object to the processing of your Personal Data at any time for a specific reason.
- The right to portability. You have the right to receive your Personal Data in a structured, commonly used and machine-readable format if we have processed your Personal Data, in particular on the basis of your consent or a contract.
To exercise your rights as described above, you can contact us at the following address: contact@fondamentalgroup.com.
If the response received has not given you complete satisfaction, you have the possibility to lodge a complaint with the Commission Nationale pour la Protection des DonnÈes (CNPD) by mail to the following address: 15, Boulevard du Jazz, L-4370 Belvaux, or by completing the online form which is available on the CNPD website (https://cnpd.public.lu/en/particuliers/faire-valoir.html).
WHO ARE THE RECIPIENTS OF YOUR PERSONAL DATA?
Your Personal Data is strictly confidential, only persons who need to know them in the exercise of their functions and are duly authorized by the Company may have access to them.
Our subcontractors and service providers may also be required to occasionally process Personal Data strictly necessary for the performance of the services we entrust to them (in particular the hosting and maintenance of the Website).
Your Personal Data may also be made accessible to any authority, jurisdiction or other third party when such disclosure is required by legal or regulatory provision or court order, or if such disclosure is necessary to ensure the protection and defense of our rights.
IS YOUR PERSONAL DATA TRANSFERRED OUTSIDE THE EUROPEAN UNION?
Some data may be transferred outside the European Union.
These transfers are based on adequacy decisions within the meaning of Article 45 of the GDPR or framed by appropriate safeguards within the meaning of Article 46 of the GDPR such as standard contractual clauses adopted by the European Commission.
HOW LONG DO WE KEEP YOUR PERSONAL DATA?
We undertake to ensure that your Personal Data is kept in a form that allows your identification for a period that does not exceed the duration necessary for the purposes for which these data are collected and processed:
PURPOSE
Management of requests for information and/or comments
DATA CATEGORY
Identification and contact data: surname, first name and e-mail address
RETENTION PERIOD
Time required to manage requests.
PURPOSE
Management of applications for job or internship offers published on the Site or spontaneous applications made via the Site
DATA CATEGORY
Application Information
RETENTION PERIOD
* Data relating to unsuccessful candidates, but who have reached the final selection phase, will be kept, for the purpose of offering them, as the case may be, new job offers, for a period of up to two years from the last contact with the company
* Data concerning candidates who have not reached the final selection phase will be deleted without delay, as soon as the recruitment procedure for the position in question is closed
* For successful candidates: integration of the data in the employee file and retention for the applicable retention period
USE OF COOKIES
What is a cookie? A cookie is a small text file stored, and/or read by your browser, on the hard drive of your device (PC, laptop or smartphone, for example) and deposited by the websites you visit. There are:
- session cookies: temporary, they expire as soon as you leave the site;
- persistent cookies: they are used to save your login data and remember your settings the next time you connect to the Site. A persistent cookie is stored as a file on your device and is retained there when you close your Internet browser;
- First-party cookies: they are deposited by the site consulted, more precisely on the site domain. They may be used for the proper functioning of the site or to collect personal data in order to track user behavior and serve advertising purposes;
- Third-party cookies: are cookies placed on domains other than that of the main site, generally managed by third parties who have been queried by the site visited and not by the user himself.
Cookie Manager. We use a cookie manager: Drupal CMS, which allows us to provide you with a Consent Management Platform (hereinafter the CMP) on our Site. This CMP allows Users to view all the cookies we use, and to consent or refuse, at any time, all or part of the cookies used when they are not necessary for the operation of the Site. Indeed, some cookies are strictly necessary to make our Website work. Because of their essential nature, CNPD is of the opinion that, under certain conditions, they do not require consent. The User has the possibility to accept or reject other cookies using the mechanism integrated into the CMP available at any time in Cookies Box.
Types of cookies used. We use several types of cookies on our Website, the characteristics of which are described below.
- Strictly necessary cookies. These cookies are necessary for the operation of the Website and cannot be disabled in our systems. They are usually established as a response to actions you have taken, such as setting your privacy preferences or filling out forms. You can set your browser to block or be informed of the existence of these cookies, but some parts of the Website may be affected. These cookies do not store any personally identifying information.
NAME
Cookie-agreed PROVIDER
GDPR
Compliance PURPOSE
Remember user choice on the acceptance/rejection of cookies EXPIRY TIME
100 days DOMAIN
First-party
NAME
Cookie-agreed-version
PROVIDER
GDPR
Compliance
PURPOSE
Remember the configuration version used by the module at the time of acceptance/rejection in order to invalidate the choice on BO parameter updates
EXPIRY TIME
100 days
DOMAIN
First-party - Audience measurement cookies. Audience measurement cookies are used to establish statistics on attendance and use of the various elements composing our Site (sections and content visited, paths). They allow us to improve its interest and ergonomics.
NAME
_Go
PROVIDER
Google Analytics*
PURPOSE
Distinguish individual users on the domain
EXPIRY TIME
2 years
DOMAIN
Third-party
NAME
_ga_<container-id>
PROVIDER
Google Analytics
PURPOSE
Allows you to preserve the state of the session
EXPIRY TIME
2 years
DOMAIN
Third-party
NAME
_gid
PROVIDER
Google Analytics
PURPOSE
Distinguish individual users from the domain
EXPIRY TIME
24 hours
DOMAIN
Third-party
NAME
_hole
PROVIDER
Google Analytics
PURPOSE
Limit the number of user requests to maintain the performance of your website
EXPIRY TIME
1 minutes
DOMAIN
Third-party
NAME
AMP_TOKEN
PROVIDER
Google Analytics
PURPOSE
Remembers a unique identifier assigned to each user in the domain
EXPIRY TIME
Configurable between 30 seconds and 1 year
DOMAIN
Third-party
NAME _gac_<property-id>
PROVIDER Google Analytics
PURPOSE Remembers a unique identifier that allows Google Analytics and ads to work together
EXPIRY TIME 90 days
DOMAIN Third-party
* All information about Google Analytics cookies is also provided by Google on their support website including:
https://support.google.com/analytics/answer/11397207?hl=fr https://support.google.com/analytics/answer/6004245
- Social media cookies. We use social network sharing buttons (LinkedIn). LinkedIn uses its own cookies and has a privacy policy, over which we have no control. Depending on your browser settings, some items may be stored on your computer. Before you can access LinkedIn, you must accept these cookies. If, in your browser, you have chosen not to accept third-party cookies, these elements will not be stored.
For more information about the cookies used by LinkedIn, please visit the dedicated page of their website directly: https://www.linkedin.com/legal/cookie-policy.
How to manage your cookies? Regarding the deposit of cookies strictly necessary for the operation of our Website, they are activated by default and do not require your consent. However, you have information about these Cookies on our CMP or in this section. Other cookies are subject to your consent. You can therefore consent to the deposit of these cookies, or refuse them, from the CMPin Cookies Box of your screen, available at any time during your visit to our Site.
CHANGES TO OUR PRIVACY POLICY
We may occasionally modify this Policy in order to comply with regulatory, jurisprudential, editorial or technical developments. If we do, we will change the "last updated" date and indicate the date the changes were made. We encourage you to check this page regularly for any changes or updates to our Policy.