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Privacy Policy

Key Luxembourg Law ("KLL") is dedicated to protecting the confidentiality and privacy of information entrusted to it. As part of this fundamental obligation, KLL is committed to the appropriate protection and use of personal information (sometimes referred to as "personally identifiable information" or "PII") that has been collected online.
Generally, our intent is to collect only the personal information that is provided voluntarily by online visitors so that we can offer information and/or services to those individuals. Please review this privacy statement ("Privacy Statement") to learn more about how we collect, use, share and protect the PII that we have obtained.

1.    Collection and use of personal information
1.1    What information we collect and for what purposes

We obtain personal information about you if you choose to provide it — for example, to contact mailboxes or to register for certain services. In some cases, you will have previously provided your personal information to KLL (if, for example, you are a former employee). Information we collect will depend on the privacy settings you have set with your social media provider, so please review the privacy statement or policy of the applicable service.
When you register or submit personal information to KLL, we will use this information in the manner outlined in this privacy statement. Your personal information is not used for other purposes, unless we obtain your permission, or unless otherwise required or permitted by law or professional standards. If you send us a resume or curriculum vitae (CV) to apply online for a position with KLL, we will use the information that you provide to match you with available KLL job opportunities.

1.2. The legal grounds we have to use your personal information

KLL generally collects only the personal information necessary to fulfill your request. Where additional, optional information is sought, you will be notified of this at the point of collection.
EU and Luxembourg data protection law allows us to process personal information, so long as we have a ground under the law to do so. It also requires us to tell you what those grounds are. As a result, when we process your personal information, we will rely on one of the following processing conditions:

  • Performance of a contract: this is when the processing of your personal information is necessary in order to take steps at your request prior to entering into a contract, or to perform our obligations under a contract to which you are party;

  • Legal obligation: this is when we are required to process your personal information in order to comply with a legal obligation, such as keeping records for legal purposes or providing information to a public body or law enforcement agency;

  • Legitimate interests: we will process information about you where it is in our legitimate interest in running a lawful business to do so in order to further that business, so long as it doesn’t outweigh your interest; or

  • Your consent: in some cases we will ask you for specific permission to process some of your personal information, and we will only process personal information in a way if you agree to us doing so. You may withdraw your consent at any time by contacting KLL at contact@kll.lu.

 

Examples of the “legitimate interests” referred to above are:

  • To offer information and/ or services to individuals who visit our website.

  • To prevent fraud or criminal activity and to safeguard our IT systems.

  • To customize individuals’ online experience and improve the performance usability and effectiveness of KLL’s online presence.

  • To conduct, and to analyze, our marketing activities.

  • To meet our corporate and social responsibility obligations.

  • To exercise our fundamental rights in the EU under Articles 16 and 17 of the Charter of Fundamental Rights, including our freedom to conduct a business and right to property.

 

In some cases, the personal data that we collect may include special categories of data, such as diversity related information (including data about racial and ethnic origin, political opinions, religious beliefs and other beliefs of a similar nature, trade union membership and data about sexual life and sexual orientation), or health data and data about alleged or proven criminal offences in each case where permitted by law.

1.3 Automatic collection of personal information

In some instances, KLL and its service providers uses cookies, web beacons and other technologies to automatically collect certain types of information when you visit us online, as well as through emails that we may exchange. The collection of this information allows us to customize your online experience, improve the performance, usability and effectiveness of KLL's online presence, and to measure the effectiveness of our marketing activities.

1.3.1 IP addresses

An IP address is a number assigned to your computer whenever you access the internet. It allows computers and servers to recognize and communicate with one another. IP addresses from which visitors appear to originate may be recorded for IT security and system diagnostic purposes. This information may also be used in aggregate form to conduct website trend and performance analysis.

1.3.2 Cookies

Cookies may be placed on your computer or internet-enabled device whenever you visit us online. This allows the site to remember your computer or device and serves a number of purposes.
On our website, a notification banner will appear requiring your consent to collect cookies. If you do not provide consent, your computer or internet-enabled device will not be tracked for marketing-related activities. A secondary type of cookie referred to as "user-input" cookies may still be required for necessary functionality. Such cookies will not be blocked through the use of this notification banner and may only be blocked through your own browser’s settings (see below). Your selection will be saved in a cookie and is valid for a period of 90 days. If you wish to revoke your selection, you may do so by clearing your browser's cookies.
Although most browsers automatically accept cookies, you can choose whether or not to accept cookies via your browser's settings (often found in your browser's Tools or Preferences menu). You may also delete cookies from your device at any time. However, please be aware that if you do not accept cookies, you may not be able to fully experience our website's features.
Further information about managing cookies can be found in your browser's help file or through sites such as www.allaboutcookies.org.

Below is a list of the types of cookies used on our website:

  • Performance (i.e., User's Browser): Our website is built using common internet platforms. This has built-in cookies which help compatibility issues (e.g., to identify your browser type) and improve performance (e.g., quicker loading of content). Such cookies are session types and deleted upon closing of the browser.

  • Security (e.g. Asp .NET) Cookies: If you register for access to a restricted area, our cookies ensure that your device is logged for the duration of your visit. You will need your username and password to access the restricted areas. Such cookies are session types and deleted upon closing of the browser.

  • Site Preferences: Our cookies may also remember your site preferences (e.g., language) or seek to enhance your experience (e.g., by personalizing a greeting or content). This will apply to areas where you have registered specifically for access or create an account. Such cookies are session types and deleted upon closing of the browser.

  • Analytical: We use several third party analytics tools to help us understand how site visitors use our website. This allows us to improve the quality and content on kll.lu for our visitors. The aggregated statistical data cover items such as total visits or page views, and referrers to our website. For further details on our use of Google Analytics, see below. Such cookies are persistent, but will delete automatically after two years if you no longer visit kll.lu.

  • Site visitor feedback: The first cookie (1) is set if the visitor is not invited to participate in the survey, and is used to ensure visitors are not invited after their first page view. The second cookie (2) is set if the visitor is invited to participate in the survey, and is used to ensure the visitor is not invited again to participate for a period of 90 days. The first type of cookies (1) are session types and deleted upon closing of the browser. The second type of cookies (2) are persistent, but will delete automatically after two years if you no longer visit kll.lu.

  • Social sharing: We use third party social media widgets or buttons to provide you with additional functionality to share content from our web pages to social media websites and email. Use of these widgets or buttons may place a cookie on your device to make their service easier to use, ensure your interaction is displayed on our webpages (e.g. the social share count cache is updated) and log information about your activities across the Internet and on our website. We encourage you to review each provider's privacy information before using any such service. For further details on our use of social media widgets and applications, see below. Such cookies are persistent, but will delete automatically after two years if you no longer visit kll.lu.

Other third-party tools and widgets may be used on our individual web pages to provide additional functionality. Use of these tools or widgets may place a cookie on your device to make their service easier to use, and ensure your interaction is displayed on our webpages properly.
Cookies by themselves do not tell us your email address or otherwise identify you personally. In our analytical reports, we may obtain other identifiers including IP addresses, but this is for the purpose of identifying the number of unique visitors to our website and geographic origin of visitor trends, and not to identify individual visitors.

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BY NAVIGATING ON OUR WEBSITE, YOU AGREE THAT WE CAN PLACE THESE COOKIES ON YOUR COMPUTER OR INTERNET ENABLED DEVICE.

1.3.3 Google Analytics

KLL may use Google Analytics. More information about how Google Analytics is used by KLL can be found here: http://www.google.com/analytics/learn/privacy.html
To provide website visitors with more choice on how their data is collected by Google Analytics, Google have developed the Google Analytics Opt-out Browser Add-on. The add-on communicates with the Google Analytics JavaScript (ga.js) to indicate that information about the website visit should not be sent to Google Analytics. The Google Analytics Opt-out Browser Add-on does not prevent information from being sent to the website itself or to other web analytics services.

1.3.4 Web beacons

A web beacon is a small image file on a web page that can be used to collect certain information from your computer, such as an IP address, the time the content was viewed, a browser type, and the existence of cookies previously set by the same server. KLL only uses web beacons in accordance with applicable laws.

KLL or its service providers may use web beacons to track the effectiveness of third-party web sites that provide us with recruiting or marketing services or to gather aggregate visitor statistics and manage cookies.

You have the option to render some web beacons unusable by rejecting their associated cookies. The web beacon may still record an anonymous visit from your IP address, but cookie information will not be recorded.

In some of our newsletters and other communications, we may monitor recipient actions such as email open rates through embedded links within the messages. We collect this information to gauge user interest and to enhance future user experiences.

1.3.5 Location-based tools

KLL may collect and use the geographical location of your computer or mobile device. This location data is collected for the purpose of providing you with information regarding services which we believe may be of interest to you based on your geographic location, and to improve our location-based products and services.

1.4 Social media widgets and applications

KLL website may include functionality to enable sharing via third party social media applications, such as the Facebook Like button and Twitter widget. These social media applications may collect and use information regarding your use of KLL website (see details on 'Social Sharing' cookies above). Any personal information that you provide via such social media applications may be collected and used by other members of that social media application and such interactions are governed by the privacy policies of the companies that provide the application. We do not have control over, or responsibility for, those companies or their use of your information.
In addition, KLL website may host blogs, forums, crowd-sourcing and other applications or services (collectively "social media features"). The purpose of social media features is to facilitate the sharing of knowledge and content. Any personal information that you provide on any KLL social media feature may be shared with other users of that social media feature (unless otherwise stated at the point of collection), over whom we often have limited or no control.

1.5 Children

KLL understands the importance of protecting children's privacy, especially in an online environment. In particular, our site is not intentionally designed for or directed at children under the age of 13. It is our policy never to knowingly collect or maintain information about anyone under the age of 13, except as part of an engagement to provide professional services and in this case only with the appropriate consent from his or her parents or guardians.

2. Sharing and transfer of personal information

We do not share personal information with third parties, except as necessary for our legitimate professional and business needs, to carry out your requests, and/ or as required or permitted by law or professional standards. In addition, KLL may transfer certain personal information outside of the EEA to outside companies working with us or on our behalf for the purposes described in this Privacy Statement. KLL may also store personal information outside of the EEA. If we do this your personal information will continue to be protected by means of contracts we have in place with those organizations outside the EEA, containing standard data protection clauses which are in a form approved by the European Commission. You may obtain a (redacted) copy of these standard data protection clauses from us upon request.
KLL will not transfer the personal information you provide to any third parties for their own direct marketing use.

3. Consent

Any time we process your PII based on your consent, you have the right to withdraw such consent. KLL may ask for your permission in order for you to receive additional information about our services and events. KLL may also ask for your permission for other uses of your PII, and you can agree to or decline those uses. If you opt-in for particular services or communications, such as an e-newsletter, you will be able to unsubscribe at any time by following the instructions included in each communication. If you decide to unsubscribe from a service or communication, we will try to remove your information promptly, although we may require additional information before we can process your request.
As described in "Cookies" above, if you wish to prevent cookies from tracking you as you navigate our site, you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. Note, however, that some portions of our site may not work properly if you elect to refuse cookies.

4. Your rights

If KLL processes personal information about you, you have the following rights:

  • Access and correction: you have the right to access to that data. This is sometimes called a ‘Subject Access Request’. If we agree that we are obliged to provide personal information to you, we will provide it to you free of charge. Before providing personal information to you, we may ask for proof of identity and sufficient information about your interactions with us that we can locate your personal information. If the information we hold about you is incorrect, you are entitled to ask us to correct any inaccuracies in the personal information. 

  • Object to processing: you have the right to object to us processing your personal information if we are not entitled to use it any more
    You can make a request or exercise these rights by contacting KLL at contact@kll.lu and we will make all reasonable and practical efforts to comply with your request, so long as it is consistent with applicable law and professional standards. 

  • Other Rights: in addition, you may have rights to have your information deleted or have its processing restricted in certain circumstances and/or to obtain copies of information we hold about you in electronic form.

​You can make a request or exercise these rights by contacting KLL at contact@kll.lu and we will make all reasonable and practical efforts to comply with your request, so long as it is consistent with applicable law and professional standards. 

5. Data security and integrity

KLL has reasonable security policies and procedures in place to protect personal information from unauthorized loss, misuse, alteration, or destruction. Despite KLL's best efforts, however, security cannot be absolutely guaranteed against all threats. To the best of our ability, access to your personal information is limited to those who have a need to know. Those individuals who have access to the data are required to maintain the confidentiality of such information. 
We also make reasonable efforts to retain personal information only for so long i) as the information is necessary to comply with an individual's request, ii) as necessary to comply with legal, regulatory, internal business or policy requirements, or iii) until that person asks that the information be deleted.  The period for which data is retained will depend on the specific nature and circumstances under which the information was collected. 

6. Links to other sites

Please be aware that KLL website may contain links to other sites, including sites that are not governed by this Privacy Statement but by other privacy statements that will often differ somewhat. We encourage users to review the privacy policy of each website visited before disclosing any personal information.

7. Changes to this statement

KLL may modify this Privacy Statement from time to time to reflect our current privacy practices. When we make changes to this statement, we will revise the "updated" date at the top of this page. Any changes to the processing of personal information as described in this Privacy Statement affecting you will be communicated to you through an appropriate channel, depending on how we normally communicate with you.

8. Policy questions and enforcement

KLL is committed to protecting the online privacy of your personal information. If you have questions or comments about our administration of your personal information, please contact us at contact@kll.lu. You may also use this address to communicate any concerns you may have regarding compliance with our Privacy Statement.

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