Please take a moment to familiarize yourself with our privacy practices.
“Binding Corporate Rules”: internal codes of conduct implemented within the entities of the IEE group allowing entities of the IEE group, located in the European Economic Area or in a country covered by an adequacy decision issued by the European Commission, to transfer Personal Data to other entities within the IEE group, located outside the EEA or in a country not covered by an adequacy decision issued by the European Commission. Those Binding Corporate Rules contain privacy principles, tools of effectiveness (audit, training, etc.) and elements proving that the rules are binding. They are approved by the Luxembourg data protection supervisory authority (the “CNPD”).
“Data Protection Law”: Regulation (EU) 2016/679 of 27 April 2016 and any applicable national data protection legislation.
“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 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, L6468 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.
“Personal Data”: any data which relates to a living individual who can be identified from that data or from that data and other information which is in the possession of, or is likely to come into the possession of, IEE (or its representatives or service providers). In addition to factual information such as name or address, it could include an expression of opinion.
“You”: each Data Subject to whom this notice is addressed, who may be a Client or prospective Client of ours, a visitor to the IEE website, an employee, director, officer or representative of another organization with which we have a business relationship, or any other Data Subject whom we may be in relation with.
Data processing controller
The data processing controller, is the designated entity that is responsible for the way your personal data is processed, transferred and retained.
The editor of the website is also the data processing controller :
IEE International Electronics & Engineering S.A.
12, rue Pierre Richardot
L – 6468 Echternach
Register of Commerce and Companies n°: B134858
Intra community VAT: LU22594664
The data processing controller can be contacted by phone (+352) 2454-1 or by email: firstname.lastname@example.org.
What personal data do we collect?
While you navigate through our website, we collect different kinds of technical data :
- web browser and screen resolution
- operating system and device type (computer, mobile, tablet)
- session statistics
- navigation feed and clicks
- IP address
This data is stored anonymously and can not be used to identify you.
How do we collect your personal data?
Only data that you voluntarily provided is being collected, such as data submitted while signing up to a newsletter, filling out a contact form or contacting us via email. Data outlining how you navigate through our website will also be collected.
Usage of your personal data
A cookie (a small text file) is placed on your device (computer, mobile phone, tablet) when you visit any website. This cookie identifies the device each time you visit the web site during the defined lifetime of the cookie. Various kinds of cookies are used on our website:
It is a type of cookie which is essential to navigate a website. If you block this type of cookies in your web browser, you may not be able to use certain features of a website. These types of cookies are only sent by our website and not by third-party tools.
Preference cookies allow us to improve and optimize the performance of our website by suggesting customized features (eg: language settings). If you block preference cookies in your browser, you will not be able to benefit from any customized features. Preference cookies are sent by the website and by third party tools.
Please consult our subcontractors at the end of this page to know what type of cookies are sent by third party providers.
Analytic cookies allow us to create performance statistics and analyze user behavior on our website. The collected data is crucial for our business, as well as long term website optimization measures.
We assume that we have a legitimate interest to send this type of cookies and that your prior consent is not required.
Objection to the usage of cookies
Some of our subcontractors offer “opt-out” options, which will block data collection and tracking:
- Google Analytics
Most web browser settings will allow you to set alerts if a website is trying to install cookies on your device or limit the type of cookies you allow. Check your web browser settings to find out which cookies you are allowing.
Personal data is collected based on the following legal grounds :
- Preparation and execution of service contracts
- To adapt and improve the offer
- To comply to legal obligations
- For our legitimate interest
- To defend our interests during legal procedures
- For commercial purposes, if we have received your consent
How long is your data stored for?
Your data is only kept as long as we estimate for it be necessary to achieve the initial goal. All personal data is stored for a defined period of time depending on the type of data. The retention period may differ depending on the purpose of the data collected such as:
- legal and contractual retention periods
- the limitation period during which the concerned persons may assert their legal rights against our company
- good practice
- Company’s commercial goals
The maximum retention period of your personal data does not exceed 10 years.
Protection of your personal data
We use different technical and organizational methods to protect your personal data from unauthorized access.
To which countries is your personal data transferred to?
Personal data may be shared internally for company purposes and with different third party providers in accordance with their contractual arrangements. Selected data may be transferred to third party providers as part of an outsourcing contract. All third party providers have confirmed to treat and process any data in accordance with GDPR (General Data Protection Regulation) as of 25th May 2018.
According to the (EU) 2016/679 regulation on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, you benefit from a certain number of rights. Upon request, we will grant you access to any collected data. You have the right to request any modification of your data or you can request for it to be deleted permanently. You also have the right to withdraw your consent at any moment in time, and oppose any further processing of your data for a legitimate reason.
Please note that some of the rights outlined above may be restricted if we have a superior interest or a legal obligation to pursue data processing.
If you want to act upon your rights, please contact the data processing controller outlined at the top of this document.
You also have the right to submit a formal complaint to the Commission nationale pour la protection des données having its registered office at 1 Avenue du Rock’n’Roll, L-4361, Esch-sur-Alzette, Luxembourg.
No unlawful or unacceptable content posting
You are not authorized to post on or transmit to the Site any unlawful, threatening, libellous, defamatory, obscene, scandalous, inflammatory, pornographic, or profane material, or any other content that could give rise to any civil or criminal liability under any applicable law. If you do so, you agree to assume all claims, costs, losses, expenses, damages and liabilities caused by such activity and indemnify and hold IEE harmless from any liability or loss.
You may provide hyperlinks to other internet websites maintained by third parties or may provide third party content on the Site for as long as such content or website is freely available. The content in any such linked sites is not under IEE control and IEE is not responsible for the content of those sites, including any further links to other sites. If you decide to access any of the third party sites linked to the Site, you do so entirely at your own risk. It is up to you to take precautions to ensure that the third party you link to for your use is free of computer viruses, worms, Trojan horses and other items of destructive nature.
By providing a link, IEE does not necessarily endorse a third party or its website and IEE shall not be responsible for other sites’ content etc. IEE makes no warranties of any kind, express or implied, with respect to such links and reserves the right to terminate a link to a third party website at any time in its sole discretion.
Link to the Site
By linking to the Site, the linking party agrees to defend, indemnify and hold IEE and its officers, directors, employees, affiliates, agents, licensors and business partners harmless from and against any and all losses, costs, damages, liabilities and expenses including, without limitation, attorney’s fees and costs of defense arising from or in relation to any such link. IEE has no liability for any indirect, exemplary, incidental, punitive, special or consequential damages of any kind with regard to the linking or use of such link.
If you wish to provide a link to the Site, you may do so but you may not use or replicate IEE content; you agree not to create a browser, border environment or frame for IEE content; you may not imply that IEE is endorsing you or your products or services; you may not misrepresent your relationship with IEE; you may not present false information about IEE products or services; and your linked website shall not contain content that could be construed as distasteful, offensive or controversial, and/or contain content that is not appropriate for all age, racial, religious or other groups protected by law. If you violate these promises, you agree to be responsible for all claims, costs, losses, expenses, damages and liabilities associated with such acts or omissions and indemnify and hold IEE harmless from any and all damages and you agree to remove any link to IEE immediately upon the request of IEE.
No investment/financial advice
The Site content does not constitute an investment advice, and nothing therein may be construed as an offer to sell or solicitations of an offer to buy any security or other participation in any company or entity whatsoever.
No representations, legal compliance
IEE makes no representation that content or materials on the Site are appropriate or available for use outside Luxembourg. Your use of the Site and the interpretation and application of the Terms as well as any claims relating to the Site and its content and materials shall be governed by the laws of the Grand-Duchy of Luxembourg, without giving effect to any principles of conflicts of laws. You agree that for any legal action or proceeding between you and IEE for any purpose concerning these Terms or the parties’ obligations, the courts of Luxembourg-city shall have exclusive jurisdiction.
The materials on the Site are subject to applicable laws and regulations, including export control and import regulations. Neither the materials, nor any information acquired through the use of the Site, may be acquired for, shipped, transferred, or re-exported, directly or indirectly, to proscribed or embargoed countries or their nationals, nor may they be used for nuclear activities, chemical or biological weapons or missile projects without a specific license permitting such use and issued by the responsible government authority. You shall comply strictly with all applicable export laws and regulations and assume sole responsibility for obtaining necessary licenses to export or re-export.
IEE claims the copyright interest in the compilation in all the Site content, including without limitation, the incorporated websites.
Please note that the names, logos, title design and trademarks owned by IEE may not be used without IEE’s express written permission.
All users of the Site consent to these Terms. You may update or change information related to your person or forward any other questions or concerns about this policy by contacting IEE (contact details below).
Attn. of General Counsel
12 rue Pierre Richardot, L-6468 Echternach
Tel: +352 2454 1
Fax: +352 2454 3200
RCS Luxembourg B 134.858
TVA ID: LU225 946 64
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
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 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.
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:
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 or specific measures (such as adequate contractual arrangements) 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 Binding Corporate Rules.
Your rights and how to exercise them
IEE seeks to ensure that you are able to exercise your rights at any time. IEE will address any request within the limits of its technical and organizational means and to the fullest extent required under the Data Protection Law.
- Right to access your Personal Data: should you want to review the Personal Data we hold, collect and process about you, please let us know by using the contact information provided in the section “HOW TO CONTACT US” of this policy.
- Right to rectification: should the Personal Data we hold, collect and process about you be inaccurate or incomplete, you have the right to update such Personal Data at any time by contacting us by using the contact information provided in the section “HOW TO CONTACT US” of this policy.
- Right to erasure: if at any time you decide you do not want us to retain any Personal Data we collected from you, you may request we delete your Personal Data by contacting us by using the contact information provided in the section “HOW TO CONTACT US” of this policy. We will take reasonable measures to comply with your request in accordance with applicable laws.
- Right to restriction of processing: should you wish to exercise this right (i.e. the right to obtain that, under certain circumstances, the processing of your Personal Data should be restricted to storage of such Personal Data unless your consent has been obtained), please contact us by using the contact information provided in the section “HOW TO CONTACT US” of this policy.
- Right to object: should you wish to exercise this right (i.e. the right to object, on grounds relating to your particular situation, to the processing of your Personal Data, unless we can either demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms or that we need to process the Personal Data for the establishment, exercise or defense of legal claims), please contact us by using the contact information provided in the section “HOW TO CONTACT US” of this policy. We will consider your objection and we will comply with it unless we have a compelling legitimate ground as permitted by applicable law. This right may always be exercised in the case of direct marketing.
- Right to data portability: you have the right to have your Personal Data transmitted directly from us to another data controller only when you have asked us to do so and have consented to such sharing, and when technically feasible. Should you wish to exercise this right, please contact us by using the contact information provided in the section “HOW TO CONTACT US” of this policy.
- Right to lodge a complaint with the supervisory authority: you have the right to lodge a complaint with the Commission Nationale pour la Protection des Données (the “CNPD”) or with the data protection supervisory authority competent in your EU Member State of residence, where you believe that your Personal Data is being processed in a way that does not comply with the Data Protection Laws.
How we protect your personal data
IEE acknowledges your trust and is committed to protecting the Personal Data you provide to us. We endeavour to protect Personal Data by using adequate security measures (maintained and improved over time in line with legal and technological improvements) and by putting in place contractual limitations on the use of the Personal Data, as the case may be.
Notification of personal data breach
IEE will notify you of any Personal Data breach by IEE, its processors, or any other third-parties acting on IEE’s behalf without undue delay, only where the Personal Data breach is likely to result in a high risk to your rights and freedoms.
Retention period of personal data
IEE will only retain your Personal Data:
- For as long as it is necessary for the purpose or purposes for which its processing was intended;
- For the duration of our contractual relationship with you or the organization that you represent;
- For as long as required or permitted by law.
How to contact us
Personal Data that we collect when you apply online for employment: you may submit Personal Data to be considered for employment at IEE. Such information includes, amongst others, your name, your address, your phone number, your email address, experience, education, job skills and other information contained on your curriculum vitae (CV) and/or your cover letter. IEE uses such Personal Data solely for consideration of your candidacy for employment, to communicate with you and to generate related correspondence, including offer letters and employment contracts. Such data may also be used, subject to applicable local laws, to conduct necessary background checks for compliance and other employment related purposes (including the assessment of your profile in view of the conclusion of a potential employment contract, to the extent permitted by applicable laws and regulations). Finally, IEE only retains such Personal Data for as long as necessary to address your employment application and any questions that may arise regarding your application’s processing.
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