Privacy policy

1. Who we are
   • “We”, “us” or “our” means FREIIA Luxembourg SARL Simplifiée, with its registered office at 63, Rue de Hollerich, L-1741Luxembourg, with trade register number B279846 and VAT number LU35125056. We act as the controller for the personal data we gather through your use of our website.
   • This Privacy Policy is solely intended to provide you with information regarding the processing of personal data through your use of the website. For our privacy practices in relation to our services, we refer you to the agreement that may be concluded between us.
   • Our website, (https://www.freiia.lu), is owned by FREIIA Luxembourg SARL Simplifiée and is managed and hosted by Ionos SARL, with its registered office at 7, Place de la Gare, BP 70109, F-57200 Sarreguemines Cedex, France, with trade register number (SIREN) 431 303 775, Siret number 431 303 775 000 16 and VAT number FR13 431 303 775. For further information, please read article 5 of this Privacy Policy.
   • Your privacy is important to us, so we have developed this Privacy Policy that sets out how we collect, disclose, transfer and use (“process”) the personal data that you share with us, and which rights you have. Please take a moment to read through this policy.
   • If you have any questions, concerns or complaints regarding this Privacy Policy or our processing of your personal data, or if you wish to submit a request to exercise your rights as set out in article 4, you can contact us:
     • Via-mail: contact@freiia.lu
     • By post:
       DPO of FREIIA Luxembourg SARL Simplifiée
       63, Rue de Hollerich
       L-1741 Luxembourg
2. How we use and collect your personal data
   • Personal data is defined as any information relating to an identified or identifiable natural person. Identifiable refers to identifiers (such as name, identification number, location data, etc.), that can be used to directly or indirectly identify a natural person.
   • The personal data we collect is used for the purposes listed hereunder:
     • If you use the contact form on our website, we will use your personal data to reply to your query, via e-mail or telephone. Your e-mail address will also be included in our database for sending our newsletter and providing information on events, seminars, etc.
     • If you send us an unsolicited application or CV, or if you respond to a vacancy, we may use your personal information to inform you about the status of your application or retain your information for the purposes of establishing a recruitment reserve, as we are always looking for partnerships with people who want to boost their careers or create an opportunity in some other way.
     • We process your personal data to support the website and enhance your user experience, which includes ensuring the security, availability, performance, capacity and health of the website.
     • We process your personal data to enforce or exercise any rights that are available to us based on applicable law, such as use for the establishment, exercise or defense of legal claims.
     • We may also use your personal data to fulfil our obligations as set out by applicable law.
   • The following categories of personal data can be distinguished:
     • Contact data: if you use the contact form, you will be asked to provide the following information: name, e-mail address, phone number, and any personal data you choose to put in the designated blank field “Message” (please do not provide us with any sensitive information, such as health information, information pertaining to criminal convictions, or credit card/account numbers) or other documents as annexed (such as CVs). This is information provided directly by you.
     • Usage data: We collect personal data regarding your activities on our website: the referrer (previously visited website), requested website or file, browser type and version, operating system used, device type used, time of access, and the IP address in anonymized form, which is used solely to determine the location of access. This information may be aggregated and used to help us provide more useful information regarding the use of our website. If the usage data is completely anonymized (and can therefore not be traced back to you as an individual), this will not be considered personal data for the purpose of this Privacy Policy. This is personal data automatically collected through your use of the website.
   • The legal basis for the processing of your personal data is:
     • Contractual ground: the processing is necessary for the execution of the commitments made in our agreement.
     • Consent: We have received this unambiguous and explicit consent. You have the right to withdraw your consent at any time. This will not affect the lawfulness of the processing carried out prior to the withdrawal of your consent.
     • Legitimate interest: The processing is necessary for the protection of legitimate interests, i.e. to support our website and improve its user-friendliness.
   • In the event the legal basis for the processing of your personal data is consent, you will, at all times, have the right to withdraw your consent. This will, however, not affect the lawfulness of any processing done prior to the withdrawal of consent. If the legal basis for processing is our legitimate interests the public interest, you will have the right to object to such processing, as set out in article 4 of this Privacy Policy.
   • Your personal data will solely be used for the purposes as set out in this article.
3. Retention of your data and deletion
   • Your personal data will not be kept longer than necessary for a specific purpose and will be kept for a maximum of 1 year, unless a longer period is necessary to achieve the purposes for which it was collected. In the event of a longer period, we will always ask for your consent.
   • By submitting your CV and/or other personal details via the contact form or by e-mail, you agree that your details will be kept and passed on to our company owners and employees with a view to finding an opportunity, suitable position or vacancy. These data will be kept to a maximum as stipulated in the agreement concluded with you or, if we would not find a suitable position for you, for a period of 5 years to contact you within the context of our recruitment reserve, unless you would object to this.
   • If you withdraw your consent or you object to our use of your personal data, and such objection is successful, we will remove your personal data from our databases. Please note that we will retain the personal data necessary to ensure your preferences are respected in the future.
   • The foregoing will, however, not prevent us from retaining any personal data if this is necessary to comply with our legal obligations, in order to file a legal claim or defend ourselves against a legal claim, or for evidential purposes.
4. Your rights
   • This article lists your principal rights under data protection law. We have tried to summarize them for you in a clear and legible way.
   • To exercise any of your rights, please send us a written request in accordance with article 1 of this Privacy Policy. We will respond to your request without undue delay, but in any event within one month of the receipt of the request. In the event of an extension of the term to respond or in the event we do not take action on your request, we will notify you.
   • The right to access
     • You have the right to confirmation as to whether or not we process your personal data and, if we do so, you have the right to access such personal data, together with certain additional information that you also find listed in this Privacy Policy.
     • You have the right to receive from us a copy of your personal data we have in our possession, provided that this does not adversely affect the rights and freedoms of others. The first copy will be provided free of charge, but we reserve the right to charge a reasonable fee if you request further copies.
   • The right to rectification
     • If the personal data we hold about you is inaccurate or incomplete, you have the right to have this information rectified or, taking into account the purposes of the processing, completed.
   • The right to erasure (right to be forgotten)
     • In some circumstances, you have the right to the erasure of your personal data without undue delay. Those circumstances include:
       • The personal data are no longer needed in relation to the purposes for which they were collected or otherwise processed;
       • You withdraw your consent, and no other lawful ground exists;
       • The processing is for direct marketing purposes;
       • The personal data have been unlawfully processed; or,
       • Erasure is necessary for compliance with EU law or Luxembourgish law;
     • There are certain exclusions to the right to erasure. Those exclusions include where processing is necessary:
       • for exercising the right of freedom of expression and information;
       • for compliance with a legal obligation; or,
       • for the establishment, exercise or defense of legal claims.
   • The right to restrict processing;
     • You have the right to restrict the processing of your personal data (meaning that the personal data may only be stored by us and may only be used for limited purposes), if:
       • You contest the accuracy of the personal data (and only for as long as it takes to verify that accuracy);
       • The processing is unlawful and you request restriction (as opposed to exercising the right to erasure);
       • We no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defense of legal claims; or,
       • You have objected to processing, pending the verification of that objection.
     • In addition to our right to store your personal data, we may still otherwise process it but only:
       • with your consent;
       • for the establishment, exercise or defense of legal claims;
       • for the protection of the rights of another natural or legal person; or,
       • for reasons of important public interest.
     • We will inform you before we lift the restriction of processing.
   • The right to data portability
     • To the extent that the legal basis for our processing of your personal data is consent, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
     • You also have the right to have your personal data transferred directly to another company, if this is technically possible, and/or to store your personal data for further personal use on a private device.
   • The right to object to processing
     • You have the right to object to the processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for:
       • The performance of a task carried out in the public interest or in the exercise of any official authority vested in us;
       • The purposes of the legitimate interests pursued by us or by a third party.
     • If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims.
     • You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
   • The right to complain to a supervisory authority
     • If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work, or the place of the alleged infringement. In Luxembourg, you can submit a complaint to the National Commission for Data Protection (Commission Nationale pour la Protection des Données - CNPD), 1 Avenue du Rock’n’Roll, L-4361 Esch-sur-Alzette (contact@cnpd.lu).
5. Providing your personal data to others
   • In order to provide you with our website, we work with service provider to process and store your personal information. We use the following categories of service providers:
     • Hosting provider: Ionos SARL, with its registered office at 7, Place de la Gare, BP 70109, F-57200 Sarreguemines Cedex, France, with trade register number (SIREN) 431 303 775, Siret number 431 303 775 000 16 and VAT number FR13 431 303 775. For more information, visit the website (in French): https://www.ionos.fr/terms-gtc/terms-imprint/?source=termsandconditions
     • Datacenter: Digital Realty Management France SARL, with its registered office at 129, Boulevard Malesherbes, F-75017 Paris 17, France, with trade register number (Siren) 519 287 833, Siret number 519 287 833 000 56 and VAT number FR55 519 287 833. For more information, visit the website: https://www.digitalrealty.com/data-centers/emea/paris
   • Our hosting provider Ionos SARL uses WebStat, a tool provided by Ionos and used by MyWebsite Now to collect data about website visitors. The purpose of this data collection is to perform statistical analysis and technical optimization of the website. This helps website owners understand how their site is used and improve its performance. 
   • The data is collected either through a pixel or a log file. To protect personal data, WebStat does not use cookies.
   • When the tool records a visitor's access to a page on your website, the visitor's IP address is also detected. However, the IP address is immediately anonymized and processed without any reference to the individual.
   • Ionos does not store any data that would allow personal conclusions to be drawn about visitors to our website. The following data is collected from website visitors:
     • Referrer (previously visited website).
     • Requested website or file.
     • Browser type and browser version.
     • Operating system used.
     • Device type used.
     • Time of access.
     • IP address in anonymized form (used only to determine the location of access).The data is collected out of necessity to ensure the security and proper functionality of the website, as well as the account.
   • Personal data will not be passed on to third parties.
   • There is no transfer of Personal Data by Ionos SARL to third countries outside the European Economic Area.
   • The Datacenter service provider, Digital Realty Management France SARL, does not process website visitor data from Ionos-hosted websites.
   • For more information, please read following websites (in French):
     • https://www.ionos.fr/assistance/protection-des-donnees/traitement-des-donnees-des-visiteurs-du-site-web-de-votre-produit-ionos/mywebsite-now-offre-actuelle-de-notre-boutique-client/
     • https://www.ionos.fr/assistance/protection-des-donnees/traitement-des-donnees-des-visiteurs-du-site-web-de-votre-produit-ionos/webstat/
   • We do not use use software or services of further external providers such as WordPress, Joomla or Google Analytics. Thus, your data is not processed by these providers.
   • We may disclose your personal data in the event such disclosure is required or necessary in order to fulfil a legal obligation. We may also disclose personal data in order to protect your vital interests or the vital interest of another natural person
   • As such, we do not disclose your personal data to our social media partners. However, we use social media plugins to direct you to our social media channels and to allow you to interact with our content. The social media channel used is LinkedIn. In the event you click such a link, the social media service provider may collect personal data about you and may link this information to your existing profile on such social media.
   • We are not responsible for the use of your personal data by such social media service provider. In such a case, the social media service provider will act as the controller. For your information only, we have included the relevant links (these may be changed from time to time by the relevant service provider):
     • LinkedIn: http://linkedin.com/legal/privacy-policy.
6. International transfers
   • We will not transfer your personal data outside of the European Economic Area.
7. Cookies
   • Our website may use cookies. For further information relating to our use of cookies, we refer you to our Cookies Policy.
8. Amendments to the privacy policy 
   • From time to time, we have the right to modify this Privacy Policy. You will always be able to consult the most recent version of the Privacy Policy on the website. If any amendment will affect you directly, we will resubmit the amended Privacy Policy to you and, where necessary, request your consent.

Latest update: 28/04/2025