Cookies and Data Protection Notice

1. What is the purpose of this notice?

This Cookies and Privacy Notice (this “Notice”) explains how LUXHUB S.A. (“LUXHUB”, “we”, “us” or “our”) collects, uses, shares and otherwise processes your Personal Data when interacting with you through LUXHUB website, developer portal, or service desk and/or other applicable platforms (“LUXHUB Platforms”), as notified to you from time to time.

Within the context of your use of LUXHUB Platforms, LUXHUB acts as data controller.

By exception thereto, when the processing is performed in the name and on behalf of an API provider, for instance when LUXHUB is interacting with a natural person representing an API consumer for the purpose of enabling the latter consuming an API provider’s API, LUXHUB acts as data processor of such API provider.

The present Notice encompasses both the description of processing performed by LUXHUB as data controller on the one hand as well as data processor of the API provider on the other hand. In the event of questions related to the processing of Personal Data performed by a given API provider, we do invite you to contact the relevant API provider’s data protection team, whose contact details are provided on the API provider’s website.

2. What Personal Data do we process?

When using the term “Personal Data” in our Privacy Notice, we mean information that relates to you and allows us to identify you, either directly or in combination with other information that we may hold. Your Personal Data may include for example your name, your contact details or information on how you interact with us.

Categories of data processed

Data category	Type
Personal identification data	· Name and surname
	· Title
	· Postal and/or e-mail address
	· Phone numbers
	· Date of birth
	· Salutation (Mr / Mrs / Ms)
Professional information	· Job title
	· Department and name of organization
	· Professional postal and/or e-mail address
	· Professional phone numbers

Special categories of Personal Data

In specific circumstances (e.g. Personal Data provided in a CV), we may collect information that could reveal your racial or ethnic origin or conviction of criminal offences. Such information is considered to fall in the special categories of Personal Data. We only process this information in the case you have given your explicit consent, it is necessary according to legal obligations, to establish, exercise or defend legal claims or you have deliberately made it public.

By providing any “sensitive” Personal Data you understand that we may collect and use it in order to fulfil the purpose in the context of which they have been disclosed and in accordance with this Notice.

If you do not allow us to process such Personal Data, this may lead to us being unable to fulfil the purpose for which such Personal Data were supposed to be processed.

3. How and why your Personal Data are processed

Depending on your use of the LUXHUB Platforms, your Personal Data are processed for the following purposes:

To provide you with requested information and services, handle complaints (“Communication”)
To identify services that may interest you, communicate with you about our offerings (such as through newsletters or events), and to establish or maintain a professional relationship (“Marketing and Relationship Management”)
To maintain, develop and improve the LUXHUB Platforms and social media pages, in particular by generating statistics regarding their use (“Analytics”)
To protect the LUXHUB Platforms (“Security”)
To personalize and improve your user experience (“Improvement”)
To exercise rights by establishing, exercising or defending a legal claim or in order to defend itself against a legal claim from third parties (“Dispute Resolution”)
To handle your job application and assess your eligibility to work with us (“Recruitment”)

Your Personal Data are solely processed for the purposes for which they were collected and which you have been informed about, unless we (or the API provider, as the case may be) reasonably consider that it is necessary to use it for another reason which is compatible with the original purpose. If a use of your Personal Data is necessary for an unrelated purpose, you will be notified and provided with the lawfulness basis allowing to do so.

Your Personal Data will be processed if and to the extent a lawful basis enables such processing. Your Personal Data will be processed based on the following lawfulness basis:

Communication:
- LUXHUB’s (or API Provider’s, as the case may be) legal obligation where such a communication is imposed by a legal or regulatory requirement,
- LUXHUB’s (or API Provider’s, as the case may be) legitimate interest where such communication is performed in the context of an agreement entered into with the company you are representing or in the event you want to be provided with information about our company or our products.
Marketing and Relationship Management: either we collect your consent, or we base our processing on our legitimate interest to maintain the relationship with you and keep you updated on our company’s development.
Analytics: either we collect your consent, or we perform this processing based on our legitimate interest.
Security: LUXHUB’s legitimate interest to protect its assets and infrastructures.
Improvement: LUXHUB’s legitimate interest to improve its services and enhance the user experience.
Dispute Resolution: LUXHUB’s or API Provider’s, as the case may be, legitimate interest to be able to exercise its rights and to defend itself against legal claims.
Recruitment: we process your Personal Data based on your consent, our legitimate interests to recruit integer and qualified professionals, or as necessary in the context of the intention to enter into a contract with you.

4. Your rights in relation to your Personal Data

Under the GDPR you have rights as an individual which you can exercise under certain circumstances in relation to your Personal Data that we hold. These rights are to:

request access to your Personal Data (commonly known as a “data subject access request”) and request certain information in relation to its processing;
request rectification of your Personal Data;
request the erasure of your Personal Data;
request the restriction of processing of your Personal Data;
request the portability of your Personal Data;
object to the processing of your Personal Data.

If you want to exercise one of these rights please contact us at dataprotection@luxhub.com or the relevant API provider, as the case may be.

You also have the right to lodge a complaint at any time with the National Commission for Data Protection (“CNPD”), the Luxembourg supervisory authority for data protection issues, or, as the case may be, any other competent supervisory authority of an EU member state.

5. Security of your Personal Data

We are committed to taking appropriate technical and organizational measures to protect your Personal Data against unauthorized or unlawful processing and against accidental loss, destruction or damage.

All your Personal Data in electronic format will be stored within the European Union. Any Personal Data in physical form will be kept in a secure location at our premises in Luxembourg.

6. Retention period

LUXHUB or the API provider, as the case may be, will only retain your Personal Data for as long as needed in order to fulfil the purposes for which it was collected and processed, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements.

In some circumstances LUXHUB may anonymize your Personal Data so that it can no longer be associated with you, in which case it is no longer considered as Personal Data. Upon expiry of the applicable retention period, we will securely destroy your Personal Data in accordance with applicable laws and regulations.

7. Sharing your Personal Data

Please note that 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. You are further hereby informed that LUXHUB might use tools provided by suppliers to process Personal Data (e.g. in the context of our CRM).

8. Cookies

When you visit LUXHUB Platforms, cookies may be automatically installed and temporarily saved in your computer in order to make it easier for you to navigate around LUXHUB Platforms. Cookies do not enable us to identify you, but are used to record information about the pages you have viewed on LUXHUB Platforms, the date and time of your visit to the site, etc.

To manage your cookies, you can visit the help page of your web browser:

Matomo

LUXHUB Platforms use Matomo as web analytics service. The processing of Personal Data with Matomo is based on legitimate interest of LUXHUB.

Matomo is used to analyse the behaviour of LUXHUB’s Platforms visitors to identify potential pitfalls; not found pages, search engine indexing issues, which contents are the most appreciated, etc.

Personal data processed by Matomo:

Matomo is processing the following Personal Data:

Cookies
IP address
User ID
Custom Dimensions
Custom Variables
Order ID
Location of the user
Date and time
Title of the page being viewed
URL of the page being viewed
URL of the page that was viewed prior to the current page
Screen resolution
Time in local time zone
Files that were clicked and downloaded
Link clicks to an outside domain
Pages generation time
Country, region, city
Main Language of the browser
User Agent of the browser
Goals, Campaigns, Events
Session recording, mouse events (movements, content forms and clicks)
Form interactions
Media interactions
A/B Tests

Legitimate interest

Processing your Personal Data in the context of Matomo is helping us identify what is working and what is not on our LUXHUB Platforms . For example, it helps us identify if the way we are communicating is engaging or not and how we can organize the structure of LUXHUB Platforms better. Our team is benefiting from the processing of your Personal Data, and they are directly acting on the LUXHUB Platforms. By processing your personal data, you can profit from LUXHUB Platforms which are getting better and better.

Without the data, we would not be able to provide you the service we are currently offering to you. Your data will be used only to improve the user experience on LUXHUB Platforms and help you find the information you are looking for.

Recipient of the Personal Data

The Personal Data received through LUXHUB Platforms are sent to:

Our company.
Matomo: “InnoCraft, 7 Waterloo Quay PO625, 6140 Wellington, New Zealand”. (Matomo cloud privacy policy)

Google ReCAPTCHA v3

LUXHUB Platforms use Google reCAPTCHA v3 as a security measure to protect LUXHUB Platforms from spam, abuse, and unauthorized access. The processing of Personal Data with Google reCAPTCHA v.3 is based on our legitimate interest in maintaining the security and integrity of LUXHUB Platforms. Google reCAPTCHA v3 is used to analyse the behaviour of LUXHUB Platforms’ visitors to distinguish between human users and automated bots attempting to access LUXHUB Platforms.

Personal Data processed by Google ReCAPTCHA v3

Google reCAPTCHA v3 is processing the following Personal Data:

Cookies
IP address
User agent of the browser
Browser language
Time and date
Screen resolution
Mouse movements and clicks
Form interactions

Legitimate Interest

We use Google reCAPTCHA v3 to protect LUXHUB Platforms and our users from malicious attacks, such as bots and spam. Our legitimate interests in using reCAPTCHA v3 include ensuring the safety and security of LUXHUB Platforms, protecting our users’ personal information, and preventing fraudulent activities. By using reCAPTCHA v3, we are able to authenticate the legitimacy of human users without the need for them to complete any challenging tasks or puzzles, which ultimately enhances their user experience on LUXHUB Platforms.

Recipient of Personal Data

The Personal Data received through https://marketplace.luxhub.com/register are sent to:

Google Ireland Limited: “Gordon House, Barrow Street, Dublin 4, Ireland”

9. Fees

You will in general not have to pay a fee to exercise any of your individual rights mentioned in this 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.

10. Updates to our Notice

We reserve the right to update this Notice at any time, and we will make an updated copy of such Notice publicly available.

11. Contact information

If you have any concerns or require any further information, please do not hesitate to contact us at dataprotection@luxhub.com or send your request to the following address:

LUXHUB

Attn. DATA PROTECTION

153-155 rue du Kiem

L-8030 Strassen

Last updated on 10 September 2024