Anpora Lux understands that your privacy is important to you and that you care about how your personal data is used and shared online.
We respect and value the privacy of everyone who visits this website, www.anporalux.lu (“Our Site”) and will only collect and use personal data in ways that are described here,
and in a manner that is consistent with Our obligations and your rights under the law.
Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of Our Privacy Policy is deemed to occur upon your first use of Our Site.
If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.
| 1. |
Definitions and Interpretation |
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In this Policy, the following terms shall have the following meanings: |
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| “personal data” |
means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site.
This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and
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| “We/Us/Our/Anpora Lux” |
means Anpora Lux S.A., a Société Anonyme registered in Luxembourg, whose registered address is 48 rue de Bragance - L-1255 Luxembourg - Luxembourg.
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| 2. |
Information About Us |
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| 2.1 |
Our Site is owned and operated by Anpora Lux S.A., a Société Anonyme registered in Luxembourg, whose registered address is 48 rue de Bragance - L-1255 Luxembourg - Luxembourg.
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| 2.2 |
Our VAT number is LU16158651 for invoicing purpose. |
| 2.3 |
Our Data Protection Officer is Alexandra Da Silva, and can be contacted by email at adasilva@anporagroup.lu, by telephone on +352 22 59 02, or by post at 48 rue de Bragance - L-1255 Luxembourg - Luxembourg. |
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| 3. |
What Does This Policy Cover? |
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This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites.
Please note that We have no control over how your data is collected, stored, or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.
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| 4. |
Your Rights |
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| 4.1. |
As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold: |
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| 4.1.1 |
The right to be informed about Our collection and use of personal data; |
| 4.1.2 |
The right of access to the personal data We hold about you (see section 12); |
| 4.1.3 |
The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 13); |
| 4.1.4 |
The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 13); |
| 4.1.5 |
The right to restrict (i.e. prevent) the processing of your personal data; |
| 4.1.6 |
The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation); |
| 4.1.7 |
The right to object to Us using your personal data for particular purposes; and |
| 4.1.8 |
Rights with respect to automated decision making and profiling. |
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| 4.2 |
If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 13 and We will do Our best to solve the problem for you. |
| 4.3 |
For further information about your rights, please contact the CNPD. |
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| 5. |
What Data Do We Collect? |
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Depending upon your use of Our Site, we may collect some or all of the following personal data: |
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| 5.1 |
name, business/company name; |
| 5.2 |
contact information such as email addresses and telephone numbers; |
| 5.3 |
demographic information such as post code; |
| 5.4 |
IP address; |
| 5.5 |
web browser type and version; |
| 5.6 |
operating system; |
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| 6. |
How Do We Use Your Data? |
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| 6.1 |
All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected.
We will comply with Our obligations and safeguard your rights under the GDPR at all times. For more details on security see section 7, below. |
| 6.2 |
Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data
(e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes: |
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| 6.2.1 |
Replying to emails from you; |
| 6.2.2 |
Contacting you by phone. |
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| 6.3 |
You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it. |
| 6.4 |
We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods
(or its retention will be determined on the following bases): |
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| 6.4.1 |
All personal data may be retained for 5 years. |
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| 7. |
How and Where Do We Store Your Data? |
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| 7.1 |
We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it. |
| 7.2 |
Your data will only be stored in Luxembourg. |
| 7.3 |
Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site. |
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| 8. |
Do We Share Your Data? |
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| 8.1 |
Subject to section 8.2, We will not share any of your data with any third parties for any purposes. |
| 8.2 |
In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings,
where We are complying with legal obligations, a court order, or a governmental authority. |
| 8.3 |
We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, and other information. All such data will be anonymised and will not include any personally
identifying data, or any anonymised data that can be combined with other data and used to identify you. |
| 8.4 |
We do not use any third-party data processors. |
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| 9. |
What Happens If Our Business Changes Hands? |
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| 9.1 |
We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business.
Any personal data that you have provided will, where it is relevant to any part of Our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will,
under the terms of this Privacy Policy, be permitted to use that data only for the same purposes for which it was originally collected by Us.
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| 9.2 |
In the event that any of your data is to be transferred in such a manner, you will not be contacted in advance and informed of the changes. |
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| 10. |
How Can You Control Your Data? |
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| 10.1 |
In addition to your rights under the GDPR, set out in section 4, when you submit personal data via Our Site, you may be given options to restrict Our use of your data. In particular,
We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in
Our emails and at the point of providing your details).
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| 11. |
Your Right to Withhold Information |
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You may access Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
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| 12. |
How Can You Access Your Data? |
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You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge.
Please contact Us for more details at gerance@anporalux.lu, or using the contact details below in section 13.
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| 13. |
Contacting Us |
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If you have any questions about Our Site or this Privacy Policy, please contact Us by email at gerance@anporalux.lu, by telephone on +352 22 59 02, or by post at 48 rue de Bragance - L-1255 Luxembourg - Luxembourg.
Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you (as under section 12, above).
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| 14. |
Changes to Our Privacy Policy |
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We may change this Privacy Policy from time to time (for example, if the law changes). Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy
on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.
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