Privacy policy

General note

Welcome to the Syngeon S.A. website. We are pleased about your visit.
It is generally possible to use our website without providing any personal data.

The use of individual services on our website may be subject to different regulations, which we would like to explain to you separately below.
Personal data is all information that can be directly or indirectly attributed to a specific natural person (e.g. name, address, e-mail address, special characteristics, etc.).
The legal basis and further information on data protection can be found in the Luxembourg law of 1 August 2018, the law of 5 May 2005 and the General Data Protection Regulation (EU) 2016/679 (GDPR). 
Your personal data will only be processed by us in accordance with the provisions of the Luxembourg

and European data protection law. Personal data is only stored if this is necessary for the provision of a service, for the provision of the website, for compliance with legal requirements or for one of the stated purposes.

The following statements inform you about the type, scope and purpose, as well as on the use and processing of personal data by the provider/controller.

Controller (Art. 4 No. 7 GDPR)

Syngeon S.A.

96,rue du Grünewald |L-1912 Luxembourg

Phone: 00352 20600188-1

E-Mail:info@syngeon.eu

1.0 Provision of the website/server log files

As a rule, it is possible to use our website without providing personal data. However, when you visit our website, certain anonymised data that is necessary to provide the website is automatically stored. This data is not personal data and is not subject to the statutory provisions of the GDPR or the Luxembourg Data Protection Act. The data are so-called server log files, which your Internet browser transmits to us or to our web space provider, where they are recorded and stored.

• Your browser type and version
• the operating system used by the user
• Your Internet Protocol address (IP address)
• Date and time
• Websites from which you visit us (referrer URL)
• Websites and content (images, files etc…) that are accessed on our website

This data is stored separately from your personal data if you have provided it. This ensures that no specific person can be identified.

1.1 Purpose of the processing of personal data

Temporary storage of the IP address is necessary to enable delivery of the website to the user. The IP address is stored for the duration of the session.

Furthermore, log files are stored to ensure the functionality of the website and to eliminate misuse and malfunctions. The data is also used to optimise and ensure the security of our information technology systems.  The data is not analysed for marketing purposes in this context.

Our legitimate interest in data processing is also based on these purposes in accordance with Art. 6 para. lit. f GDPR.

1.2 Duration of storage/deletion   

The deletion of the data mentioned under “Provision of the website/server log files” takes place as soon as the purpose for the storage no longer applies. At the latest, however, after 3 months after accessing our website.

2.0 Contact option (e-mail, contact form)

On our website, you have the option of sending us messages by e-mail and/or via a contact form.  The following mandatory information is required to contact us.

• First name and surname
• address
• Telephone number
• E-mail address

2.1 Consequences of refusing to provide mandatory information
The interested party must enable us to identify him/her by means other than the e-mail address. If the mandatory information that is important to us is refused, we will not be able to prepare an offer.

2.2 Purpose of data processing

For the purpose of processing the contact, the data voluntarily provided by the user information provided is stored. The data is stored on the legal basis in accordance with Art. 6 para. 1 lit. a GDPR.

2.3 Contract fulfilment/implementation of pre-contractual measures

As soon as a legal transaction has been concluded with us or we have received a request for a quotation, the processing becomes necessary for the fulfilment of a contract or for the implementation of pre-contractual measures. The data is processed on the legal basis of Art. 6 para. 1 lit. b GDPR.

2.4 Legal obligations
As soon as a legal transaction has been concluded with us, processing is required to fulfil legal obligations. The data is processed on the legal basis of Art. 6 para. 1 c GDPR.

3.0 Duration of storage/deletion

3.1 The data collected under point 3.1 Contact option will be deleted as soon as the purpose for which it was collected no longer applies.

3.2 The contractual fulfilment/implementation of pre-contractual measures described under point 3.2  processed data will be deleted after 10 years.

3.3 The data processed under point 3.3 Legal obligation will be deleted after 10 years.

4.0 Information on the use of cookies

• Scope of the processing of personal data
  On various pages, the web services we use utilise cookies to enable the use of certain functions of our website. Cookies are small text files that your browser can store on your computer. These text files contain a characteristic string of characters that enable the browser to be uniquely identified when you return to our website. The process of storing a cookie file is also known as “setting a cookie”.

• Legal basis for the processing of personal data
  Art. 6 para. 1 lit. f GDPR (legitimate interest). Our legitimate interest lies in maintaining the full functionality of our website, improving usability and enabling a personalised visitor approach. It is only possible to identify individual site visitors using cookie technology if the site visitor has previously provided corresponding personal data on the basis of a separate consent.

• Purpose of the processing
  Cookies are set to maintain the full functionality of our website and to improve usability. Cooke technology also makes it possible to recognise individual visitors by means of pseudonyms, e.g. an individual, arbitrary ID, so that it is possible to offer more individual services.

• Duration of storage
  Cookies are stored until they are deleted in your browser or, if it is a session cookie, until the session has expired.

• Objection and removal option
  You can set up your browser yourself according to your wishes so that the setting of cookies is generally prevented. You can then decide on a case-by-case basis whether to accept cookies or to accept cookies in principle. Cookies can be used for different purposes, e.g. to recognise that your PC has already had a connection to a website (persistent cookies) or to save recently viewed offers (session cookies). Cookies are used on our website to offer you increased user convenience. In order to be able to use these convenience functions, we recommend that you authorise the acceptance of cookies for our website. The objection and removal options are otherwise based on the general regulations on the right to object and the right to erasure under data protection law described below in this privacy policy.

5.0 Data security and data protection, communication by e-mail

Your personal data is protected by technical and organisational measures during collection, storage and processing in such a way that it is not accessible to third parties. In the case of unencrypted communication by e-mail, we cannot guarantee complete data security on the transmission path to our IT systems, so we recommend encrypted communication or the postal service for information with high confidentiality requirements.

6.0 Right to information and correction requests – Deletion & blocking of data – Revocation of consent – Right of objection

6.1 Right to information
You have the right to request confirmation as to whether we are processing your personal data. If this is the case, you have the right to information about the information specified in Art. 15 para. 1 GDPR, provided that the rights and freedoms of other persons are not affected (Art. 15 para. 4 GDPR).

6.2 Right to rectification
In accordance with Art. 16 GDPR, you have the right to have any incorrect personal data stored by us corrected at any time.

6.3 Right to erasure
In accordance with Art. 17 para. 1 GDPR, you have the right to demand that we erase the personal data collected about you if the data is either no longer required, the legal basis no longer applies due to the withdrawal of your consent, you have objected to the processing and there are no legitimate grounds for the processing, your data is being processed unlawfully, a legal obligation requires this or a collection in accordance with Art. 8 para. 1 GDPR has taken place.

The right does not exist in accordance with Art. 17 para. 3 GDPR if the processing is necessary for the exercise of the right to freedom of expression and information. Furthermore, it does not exist if it has been collected on the basis of a legal obligation or if the data serves the assertion, exercise or defence of legal claims.

6.4 Right to restriction of processing
In accordance with Art. 18 (1) GDPR, you have the right to request the restriction of the processing of your personal data in individual cases.

This is the case if

• The accuracy of the personal data is disputed
• The processing is unlawful
• The data are no longer required for the purpose of processing, but are necessary for the establishment, exercise or defence of legal claims
• An objection to the processing pursuant to Art. 21 (1) GDPR has been lodged and it is still unclear which interests prevail

6.5 Right to withdraw consent

If you have given us your express consent to the processing of your personal data in accordance with Art. 6 para. 1 lit. a GDPR or Art. 9 para. 2 lit. a GDPR, you can revoke this consent at any time. Please note that this does not affect the lawfulness of the processing carried out on the basis of the consent until revocation.

6.6 Right to object to data processing

In accordance with Art. 21 GDPR, you can object to the processing of personal data concerning you at any time, provided that the processing is carried out on the basis of Art. 6 para. 1 lit. e or f GDPR.

6.7 Right to data portability

You have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format. You may also request that we transfer this data to a third party without delay at your first instruction, provided that the processing is based on consent pursuant to Art. 6 para. 1 lit. a GDPR or Art. 9 para. 2 lit. a GDPR or a contract pursuant to Art. 6 para. lit. b GDPR and the processing is carried out by us within the framework of automated data processing, When exercising this right to data portability, you also have the right to obtain that the personal data concerning you be transferred directly to another controller, insofar as this is technically feasible. The freedoms and rights of other persons must not be affected by this.

The right to data portability does not apply to the processing of personal data necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

6.8 How you can exercise your above rights
You can exercise your rights at any time by using the contact details below.

Syngeon S.A.

96, rue du Grünewald |L-1912 Luxembourg

E-Mail:info@syngeon.eu

7.0 Right to lodge a complaint with the CNPD or another competent supervisory authority
If you suspect that your data is being processed unlawfully, you can seek judicial clarification at any time. 
Irrespective of this, you have the option of contacting the CNPD or another competent supervisory authority. You have the right to lodge a complaint in the

EU member state of your place of residence, your place of work and/or the place of the alleged infringement, i.e. you can choose the supervisory authority to which you turn at the above-mentioned locations. The supervisory authority with which the complaint has been lodged will then inform you of the status and outcome of your complaint, including the possibility of a judicial remedy pursuant to Art. 78 GDPR.