DATA PROTECTION AND COOKIE POLICY

This Data Protection and Cookie Policy (“Policy”) was prepared in order to give you more information on how the data you provide is handled by FBM, in accordance with the General Data Protection Regulation – Regulation (EU) 2016/679 (GDPR) on the protection of natural persons with regard to the processing of personal data and other applicable laws.

On handling your personal data, FBM will always be guided by a lawful, fair and clear process, using your personal data with a legitimate, relevant, adequate and limited purpose, taking all pertinent measures to keep your data secure.

 

WHICH INFORMATION IS COLLECTED, USED AND STORED AND HOW IT IS COLLECTED:

As registration is not required to navigate in the website, FBM will not collect information from you as a visitor, with the exception of the information related to the use of cookies described in this Policy.

Nonetheless, in cases you register in the website and/or make contact using the website or email, letter or other forms of communication and/or express interest in a job position and/or when you create and sign up for an account, FBM will collect basic information about you, such as your name, your city, your country, your phone number, your company’s name, your email, and other information that you freely decide to include in your message or in the files uploaded by you, i.e. information relating to identification, education, work experience, professional activity, image.

FBM does not intentionally collect any special categories of personal data, such as political opinion, religious or philosophic beliefs, genetic data (sensitive personal information), unless FBM is legally required to do so.

 

WHY INFORMATION IS COLLECTED AND HOW IT IS USED:

When you contact FBM to negotiate, become potentially a client or a provider or any other reason: FBM may collect and use the information, as applicable, to be able to contact you back; and/or to perform activity analysis of the website; and/or to comply with legal obligations, as well as to respond to and to defend FBM against legal claims; and/or to respond you and proceed in accordance to the purposes you contacted FBM for, i.e. if you contact FBM as a potential customer or provider, FBM may use your information to verify your identity and perform, for example, know your customer verification if applicable, to negotiate, to draft eventual agreement, to enter in the agreement and to perform it; and/or for accounting and auditing purposes.

When you register in the website to receive the newsletter: FBM may collect and use the information, as applicable, to be able to contact you; and/or to perform activity analysis of the website; and/or to comply with legal obligations, as well as to respond to and to defend FBM against legal claims; and/or to send you the newsletter, to update you about FBM, to inform you about FBM’s products and if applicable, to invite you for events, to estimate attendance, to organize logistics, for catering and others. If you have registered and do not wish to receive future contact, you can unsubscribe using the “Unsubscribe” link at the bottom of the received email / newsletter / email marketing.

When you create and sign up for an account: FBM may collect and use the information, as applicable, to be able to contact you; and/or to perform activity analysis of the website and its content; and/or to comply with legal obligations, as well as to respond to and to defend FBM against legal claims; and/or to monitor time of the log in, frequency and duration of it; and/or to send you the newsletter, to update you about FBM, to inform you about FBM’s products and if applicable, to invite you for events, to estimate attendance, to organize logistics, for catering and others.

When you express interest in a job position: FBM may collect and use the information, as applicable, to be able to contact you back; and/or to perform activity analyses of the website; and/or to comply with legal obligations, as well as to respond to and defend FBM against legal claims; and/or to perform direct or by third parties recruiting activities, such as research, selection of candidates, keep CV database updated for eventual future job vacancies. Also, in case the recruitment process takes place and you are selected, accept the job proposal and become an employee, the data provided shall be used mainly: to ensure effective general Human Resources and business administration, such as administrate, operate and of manage the employment relationship with you, prepare your employment contract, enter into an employment contract with you and to perform the agreement, for salary processing, to keep record of activities; and/or protect your vital interest; and/or to comply with legal obligations, as well as to respond to and defend FBM against legal claims; and/or for accounting and auditing purposes.

 

HOW INFORMATION IS STORED AND SECURED:

FBM stores your data in the server and in other IT systems, including email systems and file storage systems.

Security and confidentiality of your data is taken seriously. Access to such information is limited. We have internal controls in place to try to ensure that your data is not lost, accidentally destroyed, misused or disclosed.

Your personal information will be kept only as long as is necessary for the purpose(s) for which it was collected, and in accordance with this Policy, or during the period required by the applicable legislation and/or regulation, i.e. when you express interest for a job position and your CV is not selected, your CV is stored for a period of 18 (eighteen) months counted as of the receipt.

 

PARTIES WHO HAVE ACCESS TO INFORMATION:

FBM may only disclose your personal information outside FBM:

  • if requested by court order, legal or regulatory requirement;
  • if expressly requested by you;
  • if it is necessary to involve a third party with which FBM has a relationship, such as external services providers and/or employees of related companies;
  • eventually third parties in the context of a sale of some or all of the business. In those circumstances, the data will be subject to confidentiality arrangements.

The information which you give to FBM may be transferred to countries outside the European Union (“EU”). For example, a company of the group and/or third-party providers may be located outside of the EU.

In case FBM engages third parties to process personal data it shall be done under a duty of confidentiality. Third parties are then obliged to implement appropriate technical and organizational measures to ensure the security of data.

 

HOW YOU CAN CONTROL INFORMATION:

Your rights are guaranteed in accordance with the applicable law, including those indicated in Chapter 3 of the GDPR, as applicable, such as:

  • right of access, i.e. when you request access and copy of your data;
  • right of rectification, i.e. when asking FBM to change incorrect or incomplete data;
  • right of erasure and right to be forgotten, i.e. when you require FBM to delete or stop processing your data, where the data is no longer necessary for the purposes of the processing;
  • right to restriction of processing and right to object, i.e. where you obtain restriction of processing of your data in cases the accuracy of the data is contested by you, and/or processing is unlawful, and/or the data is no longer necessary for the purpose of processing, and/or in case of objection;
  • right to data portability;
  • right to withdraw your consent;
  • right not to be subject to a decision based solely on automated processing, including profiling;
  • right to be notified regarding rectification or erasure or restriction of processing of personal data.

In some cases, such rights may be restricted if the processing of the data is technically impossible, and/or if the information is necessary for compliance with statutory obligations, and/or if it has a lawful basis, and/or in case of FBM’s legitimate interest or third parties’ legitimate interests prevail.

If you would like to know more or exercise any of these rights, please contact: [email protected] or send a letter to the address indicated in the contact.

At the same time, if you are not satisfied with the response, you also have the right to lodge a complaint at any time with the competent supervisory authority.

In Luxembourg, the supervisory authority is the Commission Nationale pour la Protection des Données (CNPD).

 

COOKIES:

A “Cookie” is a small text file, automatically saved by the user’s computer. The website collects cookies there are essential to its functioning, as well as performance and functionality cookies. These cookies are used to help FBM to understand how the website is being used, the effectiveness of marketing campaigns, activity analysis, enhance your experience and customize your use of the website. FBM may also external services providers for fonts, maps, and videos, which may collect data such your IP address. Users of the website can configure their Internet browser in order to disable some kinds of cookies. Changes in the cookies may take effect in some cases when the page is reloaded. Blocking some cookies can impact your experience in the website. Cookies serve as identifiers for your computer, but not personally identifiable to you.

Except as otherwise set forth, the Policy will apply to the information FBM collects using cookies.

CHANGES TO DATA PROTECTION AND COOKIE POLICY:

FBM may change this Policy as needed. If changes are made, FBM will make the pertinent modifications in this website, which will be immediately implemented. It is recommended that you check this page periodically if you would like to monitor changes.

 

CONTACT:

FBM S.àr.l. (data controller)

12, rue Guillaume Schneider, L-2522 Luxembourg,

Register B159.250

Email: [email protected]

Please address it to the “Responsible for Data Protection”

Date of the last version: March 6th, 2019.