Privacy Notice

Definitions

“Client”: any recipient of our products or services, who may be an individual person or an employee, director, officer or representative of a company or intermediary client at IEE.

“Data Protection Law”: Regulation (EU) 2016/679 of 27 April 2016 and any applicable national data protection legislation.

“Data Subject”: any identified or identifiable natural person.

“IEE”, “we” or “us”: IEE International Electronics & Engineering S.A., having its central administration at 1, rue du Campus, L-7795, Bissen with registered office at 12 rue Pierre Richardot, L-6468 Echternach, Grand-Duchy of Luxembourg, or any of its subsidiaries or affiliates, details of which can be found on www.iee-sensing.com. Together these are referred to as “IEE Group”.

“(IEE) Products and Services”: the products and services that we offer to our Clients, including through our related support.

What information we collect

To provide its Products and Services, IEE needs to collect and process certain information about you. In this respect, the IEE entity determining the purposes and means for the processing of your Personal Data will act as data controller of your Personal Data. The Personal Data we collect depends on the context of your interactions with IEE, the choices you make including the Products and Services which are provided to you.

It is to be noted that you have choices about the Personal Data we collect. When you are asked to provide Personal Data, you may decline. If you choose not to provide Personal Data that is necessary to provide the Product or Service, we may not be able to deliver the Product or Service.

Categories of Personal Data processed

*The Personal Data we collect and process may include the following, but is not limited to:

– Identification data: we collect Personal Data about you such as your first and last name, email address, postal address, phone number, and other similar contact data, date and place of birth, gender, country, and preferred language;

– Business contact information: we collect Personal Data about you such as job function, job title, department, organization name, size and location, and whether or not you are acting on behalf of a client;

– Financial information: we collect your financial information, such as financial account information, if needed to make payment or fulfil contractual obligations or for related purposes;

– Contractual information: any information provided by you allowing IEE to perform its contractual duties.

– Testing information: any information provided by you enabling IEE to perform necessary tests in the context of IEE Products and Services development.

Further to the categories of Personal Data mentioned above, IEE guarantees that, except to the limited extent that may be necessary in the context of employment and in the context of performing a contract, notably related to the use of test persons in our Products and Services designing phase, we neither request nor collect special categories of Personal Data (i.e., personal information specifying criminal offences/ convictions, medical or health conditions, biometric or genetic data, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership or information specifying the sex life of the individual).

Further information about the Personal Data processed in the context of applications for a position at IEE may be found in the HR section.

How we collect data

This Privacy Notice applies to Personal Data, which is information that IEE collects from you and other third parties that specifically identifies you as an individual. IEE may collect your Personal Data in various manners.

Ways of collecting data

Information that we automatically collect when you use our Website: when you use our Website, we automatically collect, through Cookies, the following information:

• Recalling if you visited the Website before. If you are a first-time user, you might see different content compared to a regular user.
• Remembering your preferences and settings, including marketing preferences

• Remembering your specific preferences, such as if you filled in a survey, so you are not asked to do it again.

• Gathering anonymous statistics about users (only high-level information like country, repeated visits…).

Personal Data that we collect when you do business with IEE and/ or when you enter into a contractual relationship with IEE: We may collect and process your Personal Data when you conduct business and/ or enter into a contract with us (identification and contact details).

Personal Data we obtain from other sources: We also may periodically obtain both personal and non-personal information about you from IEE’s subsidiaries, affiliates, business partners or other third-party sources where they are legally permitted to share such information with us, and add it to the information we already hold about you, such as, but not limited to:

-Updated business address information;

-Identification data;

-Financial information;

-Contractual information;

-Testing information.

Personal Data that we collect when you apply online for employment: Please refer to the Human Resources (HR) section.

Purposes for collection, use and processing of Personal Data

For processing to be lawful under the Data Protection Law, a lawful basis needs to be identified before processing Personal Data.

We use or may use your Personal Data for the following purposes (or as otherwise described at the point of collection) in line with the lawful basis provided under the Data Protection Law:

• To provide you with the Product or Service you have requested;
  • Processing is necessary for the performance of a contract with the Data Subject and/or for the legitimate interests of IEE.
• To provide you with information, access to resources or other Products or Services that you have requested from us on behalf of your organization;
  • Processing is necessary for the performance of a contract with the Data Subject and/or for the legitimate interests of IEE.
• To send you client service-related communications (marketing);
  • Processing is necessary for the purposes of the legitimate interests pursued by IEE.
• To deal with communications that you send to IEE and responding to your queries, requests and complaints;
  • Processing is necessary for the performance of a contract to which the Data Subject is party or in order to take steps at the request of the Data Subject prior to entering into a contract; and/or
  • Processing is necessary for compliance with a legal obligation; and/or
  • Processing is necessary to achieve the legitimate interests of IEE.
• To fulfil our legal obligations namely in respect to our social, accounting and corporate obligations
  • Processing is necessary for compliance with a legal obligation.
• To manage the infrastructure and business operations of IEE and to comply with internal policies and procedures;
  • Processing is necessary for the purposes of the legitimate interests pursued by IEE or by a third party.
• To comply with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities.
  • Processing is necessary for compliance with a legal obligation.

In certain cases, we may also collect your explicit consent and rely upon such consent as a lawful basis for processing, for instance when we process special categories of Personal Data.

We may contact you by mail, telephone, fax, video conference, email or other electronic messaging service to notify you about special events, new features or other information that may be of interest to you in accordance with your interaction with IEE. Where required by applicable law, your prior consent will be obtained before sending you direct marketing and you may object or opt out of receiving marketing messages from IEE.

IEE does not in any way sell, lease or rent your Personal Data to third parties.

Disclosure of your Personal Data

Service providers: We may disclose/ transfer your Personal Data to third parties that we refer to as service providers solely to the extent necessary to enable such service providers to provide products or services to IEE and to assist us in providing Products or Services to you. IEE’s policy is to maintain contracts with all third parties with whom we disclose/ transfer Personal Data that restrict their access, use and disclosure of Personal Data. Service providers must, in fact, abide by our data privacy and security requirements and are not allowed to use Personal Data they receive from us for any other purpose.

Third parties: We may disclose/ transfer your Personal Data to third parties such as administration and public authorities, banking institutions, and to professional advisors and auditors of IEE.

Affiliates/branches/subsidiaries: We may disclose/ transfer your Personal Data, as provided in our Terms of Use, to other companies under common ownership or control with IEE who will process your Personal Data in a manner consistent with this Privacy Notice.

Safety, security and compliance with law: We will access, transfer, disclose and preserve Personal Data to comply with applicable law or respond to subpoenas, court orders or other valid legal process, for reasons relating to national security, to defend against legal claims, to protect the rights and safety of IEE, IEE’s clients, employees or others. This may involve the sharing of your Personal Data with law enforcement, government agencies, courts and other organizations.

The above recipients may process your Personal Data as data processors, i.e., under our instructions. They may also process your Personal Data as independent data controllers, i.e. for their own legal obligations. In the latter case, they bear all responsibility in terms of data protection.

Consent: We may share your Personal Data in other ways and for new purposes if you have asked us to do so and have consented to such sharing.

IEE shares your Personal Data as necessary to provide any Product and/or Service you have requested or authorized.

IEE may also share your Personal Data with your consent namely for the following purposes:

• Recruitment;
• Testing;

The recipients may be located in and outside the European Economic Area. Your Personal Data will not be transferred to any country outside the European Economic Area which does not ensure an adequate level of protection unless:

• You gave us prior authorization to do so ;
• If specific measures (such as Standard Contractual Clauses (SCCs)) have been taken by us in order to ensure that the requirements of the Data Protection Law have been fulfilled.

Where Personal Data is transferred/ disclosed to IEE’s affiliates/ branches/ subsidiaries located outside the EEA, such transfer is based on specific measures, specifically the model clauses issued by the European Commission with regards to transfer of personal data outside the European Union.