Empira Investment Solutions S.A. Data Protection Policy

Empira Investment Solutions S.A. takes the protection of your personal data very seriously. We process personal data collected from you when you visit our websites or in the case of further contacts, e.g. if you send us application documents or provide us with your contact details for business purposes. > Your personal data will always be processed in compliance with the applicable data protection regulations. We will neither publish your data nor pass it on to third parties without authorisation. In the following, we explain what data we collect during your visit to our website and exactly how it is used. We also inform you about the possible further data processing of your personal data, e.g. that your data is also used by us for advertising purposes (legal basis Art. 6 para. 1 letter f GDPR).

INTERNET DATA PROTECTION POLICY

Controller within the meaning of the GDPR is Empira Investment Solutions, 17, rue de Flaxweiler, L-6778 Grevenmacher, Email: datenschutz@empira-invest.lu, Phone: +352 288 065 13, Fax: +352 288 065 88.

Empira Investment Solutions S.A. takes the protection of your personal data very seriously. We process personal data collected when visiting our web pages in compliance with the applicable data protection regulations. Your data will not be published by us, nor will they be passed on to third parties without authorisation. In the following sections, we explain what data we collect during your visit to our web pages and exactly how these data are used.

  1. DATA COLLECTION AND PROCESSING WHEN ACCESSING FROM THE INTERNET

When you visit our web pages, our web servers temporarily store every access in a log file. The following data shall be recorded and stored until they are automatically deleted:

  • IP address of the requesting computer
  • Date and time of access
  • Name and URL of the retrieved file
  • Data quantity transferred
  • Message stating whether the retrieval was successful
  • Identification data of the browser and operating system used
  • Website (URL), from which the access occurred

These data are automatically transmitted by your Internet browser to our web server when accessing our website. The processing of these data occurs for the purpose of enabling the use of the website (setting up a connection), system security, technical administration of the network infrastructure and optimisation of the Internet offering. The IP address is only stored temporarily in shortened form in order to allow our web analysis tool to have the geolocation information for the page access. An evaluation does not take place at the individual person level. Personal user profiles are not created.

The legal basis for data processing is Art. 6 para. 1 lit. f GDPR.

Beyond the abovementioned cases, personal data will not be collected and processed unless you expressly consent to further processing.

  1. Use and transfer of personal data

Any use of your personal data is only for the stated purposes and to the extent necessary to achieve these purposes. Transfers of personal data to government agencies and authorities are only made within the framework of mandatory national legislation or when disclosure is required for legal and law enforcement purposes in the event of attacks on our network infrastructure. Any transfer to third parties for other purposes will not take place.

Processing of data during use of the website - Your requests

If you send us an enquiry by e-mail or via the contact form, we will collect the data you provide for processing and answering your request. We store this information for verification purposes for a period of up to two years. The legal basis for data processing is Art. 6 Para. 1 Sentence 1 lit. f GDPR.

We will not pass on your data to third parties unless this is absolutely necessary to answer your enquiry or is permitted and required by a legal basis.

  1. CONSENT TO FURTHER USE

The use of certain offers on our website, such as newsletters, requires prior registration and further processing of personal data, such as longer term storage of email addresses, user ID's and passwords. These data will only be used if you have communicated such to us and consented to the use in advance.

Applications

In connection with an application or request, whether on our website or in any other form, Empira Investment Solutions S.A. receives personal data from you, such as a CV. Empira Investment Solutions S.A. may use these personal data within the company for the purpose of deciding on employment or answering the request. In the case of applications that do not lead to hiring, the documents shall be deleted no later than six months after the closing of the application process. Application documents will only be stored for later selection procedures with your prior consent.

Orders

If you order informational material, we only use the address data given to process the order. The data will not be passed on to third parties.

Deletion

Your data will be stored after collection for as long as is necessary in compliance with the statutory retention periods for the respective task. Upon fulfilment of the purpose of the processing and upon expiration of any regulatory requirements, we will delete your personal data again.

  1. SECURITY

Empira Investment Solutions S.A. uses technical and organisational security measures to protect your personal data that we manage against accidental or intentional manipulation, destruction or access by unauthorised persons. Our security measures are continuously improved in accordance with technological developments.

We must point out that due to the structure of the Internet, unwanted data access by third parties may occur. It is therefore also your responsibility to protect your data against misuse by encrypting it or in any other way. Without appropriate protective measures, data transmitted in unencrypted form, in particular, can be read by third parties, even if this is done by e-mail.

  1. COOKIES

Cookies are only used to store technical session control data in your browser's memory. If, by way of exception, we also want to store personal data in a cookie, such as a user ID, you will be informed separately. Of course, you can also view our web pages without cookies. However, most browsers automatically accept cookies. You can prevent cookies from being saved by setting this in your browser settings. If you do not accept cookies, this may restrict the functionality of our offering.

By default, Empira Investment Solutions S.A. does not use cookies that contain personal data on its website (www.empira-invest.lu). However, the following types of cookies are set on both web pages:

Functional cookies

  • Technical cookies to distribute requests to different servers on the back end (the content of cookies does not vary by user)
  • Cookies for service measurement and observation by Microsoft. These cookie values vary by user and browser: Empira Investment Solutions S.A. receives a different value in the cookie for each computer/browser/PC user. These values are unique, but do not allow anything to be inferred about the user.

The data in the cookies will not be linked to your other data.

You can find out more about how cookies work on the http://www.allaboutcookies.org page.

  1. External Hosting

This website is hosted externally. Personal data collected on this website are stored on the servers of the host. These may include, but are not limited to, IP addresses, contact requests, metadata and communications, contract information, contact information, names, web page access, and other data generated through a web site.

The external hosting serves the purpose of fulfilling the contract with our potential and existing customers (Art. 6(1)(b) GDPR) and in the interest of secure, fast, and efficient provision of our online services by a professional provider (Art. 6(1)(f) GDPR). If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6 (1)(a) GDPR and § 25 (1) TTDSG, insofar the consent includes the storage of cookies or the access to information in the user’s end device (e.g., device fingerprinting) within the meaning of the TTDSG. This consent can be revoked at any time.

Our host(s) will only process your data to the extent necessary to fulfil its performance obligations and to follow our instructions with respect to such data.

We are using the following host(s):

cyon GmbH
Brunngässlein 12
CH — 4052 Basel

Data processing

We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the GDPR.

 

8.RIGHTS OF DATA SUBJECTS AND CONTACT DETAILS

You have the right to obtain information about personal data stored about you, the right to correct incorrect data, the right to restrict processing, the right to erase your data and the right to transfer your data. You have the right to oppose the processing of your data at any time. They have the right to object to a decision based solely on automated processing.

You have a right of appeal to the competent supervisory authority in the event of breaches of data protection law. The competent supervisory authority for data protection matters in Luxembourg is the CNPD.

If you wish to assert your rights with regard to your personal data or if you have further questions about the use of your data provided to us, please contact us as follows:

Empira Investment Solutions S.A.

Gerd Büttner - Data Protection Officer
17, rue de Flaxweiler
L 6776 Grevenmacher

Luxembourg
E-mail: datenschutzbeauftragter@empira-invest.lu

9.INTEGRATION, VALIDITY AND UPDATING OF THE DATA PROTECTION POLICY

By using our website, you consent to the use of the data described above. The data protection policy is currently valid and was issued on 11 March 2019. The further development of our web pages or the implementation of new technologies may make it necessary to amend this data protection policy. Empira Investment Solutions S.A. reserves the right to update the data protection policy at any time with effect for the future. We therefore recommend that you review the current data protection policy from time to time.

Up-to-dateness and amendment of this data protection declaration

This privacy policy is currently valid and has the status of November 2020.

It may become necessary to amend this data protection declaration as a result of the further development of our website and offers above or due to changes in legal or official requirements. The current data protection declaration can be accessed and printed out by you at https://www.empira-invest.lu/de/datenschutz.