This Cookie Policy governs the use of cookies and social media plugins on the websites of Circuit Foil Luxembourg www.circuitfoil.com (hereinafter: the “Website”).

Cookies are small text files which are stored on a device’s hard drive and which contain certain information and sometimes personal data. Social media plugins are small pieces of software developed and provided by social media service providers, which add social media integration when built into the Website.

If you want general information about how we process your personal data other than through cookies and social media plugins, including in relation to your communication with us via e-mail, phone, fax and social media and in relation to any order or purchase, please see our General Data Protection Policy.

A separate Applicant Data Protection Policy governs the processing of personal data of people who choose to apply via "Career Opportunities" of our Website.

1. IN GENERAL

1.1. The data controller of the processing of your personal data via cookies and social media plugins on the Website is Circuit Foil Luxembourg, 6 Salzbaach at L-9559 Wiltz with Data Protection Manager's company number +352 957551 52265 (hereinafter: “Circuit Foil”, “we”, “us”, “our”). You can contact us via e-mail at This email address is being protected from spambots. You need JavaScript enabled to view it..

1.2. A reference in this Cookie Policy to certain laws or regulations also includes any change, replacement or annulment of these laws or regulations, including any related executive decisions.

1.3. Circuit Foil reserves the right to, from time to time, modify, change or amend this Cookie Policy at its own discretion. Such modification, change or amendment will be communicated via the Website. If you do not accept the modifications, changes or amendments, you are to inform us by sending an e-mail to This email address is being protected from spambots. You need JavaScript enabled to view it.. If we do not receive such an e-mail from you within three (3) business days after the changes to the Cookie Policy have been announced on the Website, you will be deemed to have accepted all such changes.

2. COOKIES

2.1. You can avoid cookies being placed by configuring your browser settings as such. Guidelines about how to do this can be found here:

However, not allowing cookies when visiting the Website may cause certain or all features of the Website to stop working properly.

2.2. When you visit the Website, Circuit Foil places a number of cookies. Most data pertaining to these cookies, their placement and use allow to identify you, and Circuit Foil uses them to gain insight in how you and other visitors use the Website by gathering statistical and usage data, enabling Circuit Foil to provide a better user experience on the Website.

2.3. Circuit Foil knows about the following cookies being used on the Website:

Name

Type

Purpose

Storage period

“_pk_id#”

“_pk_ses#”

“piwik.php”

Analytical and statistical

Collects anonymous statistics on the user’s visits to the website, such as the number of visits, average time spent on the website

pk_ses : session

piwik.php : session

pk_id : 1 year

“NID”

 

Analytical and statistical

Registers a unique ID that identifies a returning user’s device. The ID is used for targeted adds.

6 months

 

2.4. You may at all times withdraw your consent with Circuit Foil’s use of cookies. To exercise this right, it suffices to delete the cookies, which have been placed on your device. To do so, you are kindly asked to refer to the appropriate instructions of your browser manufacturer, as listed above.

3. PURPOSES FOR WHICH CIRCUIT FOIL USES YOUR PERSONAL DATA

3.1. Circuit Foil processes your personal data to perform statistical analyses so that we may improve our Website, products and services or to develop new products and services.

3.2. Circuit Foil may also process your personal data for the preservation of the legitimate interests of Circuit Foil, its affiliates and partners or a third party if your registration with or use of the Website can be considered (a) a violation of this Cookie Policy or the intellectual property rights or any other right of a third party, (b) a threat to the security or integrity of any of the Website or to Circuit Foil or to any of its affiliates’ or its subcontractors’ underlying systems due to viruses, Trojan horses, spyware, malware or any other form of malicious code, or (c) in any way hateful, obscene, discriminating, racist slanderous, spiteful, hurtful or in some other way inappropriate or illegal.

3.3. Your personal data may be transferred to the police or the judicial authorities as evidence or if there are justified suspicions of an unlawful act or crime committed by you through your use of any of the Website.

4. LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA

4.1. The processing of your personal data for the purposes outlined in Article 3 above is based on a legal obligation that Circuit Foil must comply with or the legitimate interest of Circuit Foil or a third party.

4.2. When processing of your personal data is necessary for purposes of our legitimate interests, these purposes include:

  • Continuous improvements of the Circuit Foil Website, social media channels, products and services to ensure that you have the best experience possible;
  • Keeping our Website, social media channels, products and services safe from misuse and illegal activity;
  • Marketing and promotion of our products, services, brands and overall successful commercialisation of our products and services.

5. TO WHOM CIRCUIT FOIL SENDS YOUR DATA

5.1. Circuit Foil relies on third-party processors to provide you our Websites and process your personal data on our behalf. These third-party processors are only allowed to process your personal data on behalf of Circuit Foil upon explicit written instruction of Circuit Foil.

Circuit Foil warrants that all third-party processors are selected with due care and are obliged to observe the safety and integrity of your personal data.

5.2. We may share your personal data with other entities within the Circuit Foil Group of companies. However, we will ensure that all these Circuit Foil entities will take due care that all processing of your personal data is in line with what is set out in this Cookie Policy.

5.3. Circuit Foil does not send your personal data in an identifiable manner to any other third party without your explicit permission to do so. However, Circuit Foil may send anonymised data to other organisations that may use those data for improving products and services as well as to tailor the marketing, displaying and selling of those goods and services.

6. LOCATION AND TRANSFER

6.1. Circuit Foil processes your personal data within the European Economic Area (EEA). However, in order to process your personal data for the purposes outlined in Article 3 above, we may also transfer your personal data to other entities within the Circuit Foil Group or to third parties who process on our behalf outside the EEA. Each entity outside the EEA that processes your personal data will be bound to observe adequate safeguards with regard to the processing of your personal data. Such safeguards will be the consequence of:

  • The recipient country having legislation in place which may be considered equivalent to the protection offered within the EEA; or
  • A contractual arrangement between Circuit Foil and that entity. All Circuit Foil entities are parties to a contractual agreement based on the European Commission’s Standard Contractual Clauses (controller-to-controller) (Commission Decision C(2004)5721).

6.2. Circuit Foil may transfer aggregated data to organisations outside the EEA. Should such transfer take place, Circuit Foil will ensure that there are safeguards in place to ensure the safety and integrity of your data and all rights with respect to your personal data you might enjoy under applicable mandatory law.

7. QUALITY ASSURANCES

7.1. Circuit Foil does its utmost best to process only those personal data which are necessary to achieve the purposes listed under Article 3 above.

7.2. Your personal data is only processed for as long as needed to achieve the purposes listed under Article 3 above or up until such time where you object to the processing of your personal data on grounds that relate to your particular situation. This may imply that you can no longer use the whole or part of our Website. Circuit Foil will de-identify your personal data when they are no longer necessary for the purposes outlined in Article 3 above, unless there is:

  • An overriding interest of Circuit Foil, or any other third party, in keeping your personal data identifiable;
  • A legal or regulatory obligation or a judicial or administrative order that prevents Circuit Foil from de-identifying them.

7.3. Circuit Foil will take appropriate technical and organisational measures to keep your personal data safe from unauthorised access or theft as well as accidental loss, tampering or destruction. Access by personnel of Circuit Foil or its third party processors will only be on a need-to-know basis and be subject to strict confidentiality obligations.

8. YOUR RIGHTS

8.1. You have the right to request access to all personal data processed by Circuit Foil pertaining to you. Circuit Foil reserves the right to charge an administrative fee for multiple subsequent requests for access that are clearly submitted for causing nuisance or harm to Circuit Foil. Each request will specify for which processing activity you wish to exercise your right to access and will specify to which data categories you wish to gain access to.

8.2. You have the right to ask that any personal data pertaining to you that are inaccurate, are corrected free of charge. If you submit a request for correction, your request needs to be accompanied of proof of the flawed nature of the data for which correction is asked.

8.3. You have the right to request that personal data pertaining to you be deleted if this data is no longer required in the light of the purposes outlined in Article 3 above or if you successfully object to the processing of your personal data on grounds that relate to your particular situation. However, you need to keep in mind that a request for deletion will be evaluated by Circuit Foil against:

  • Overriding interests of Circuit Foil or any other third party;
  • Legal or regulatory obligations or administrative or judicial orders which may contradict such deletion.

Instead of deletion you can also ask that Circuit Foil limits the processing of your personal data if (a) you contest the accuracy of the data, (b) the processing is illegitimate, or (c) the data is no longer needed for the purposes listed under Article 3 above.

8.4. You have the right to oppose the processing of personal data if you are able to prove that there are serious and justified reasons connected with these particular circumstances that warrant such opposition. However, if the intended processing qualifies as direct marketing, you have the right to oppose such processing free of charge and without justification.

8.5. You have the right to receive from us in a structured, commonly-used and machine-readable format all personal data you have provided to us.

8.6. If you wish to submit a request to exercise one or more of the rights listed above, you can send an e-mail to the general privacy e-mail address: This email address is being protected from spambots. You need JavaScript enabled to view it.. A request to exercise a right will not be construed as consent with the processing of your personal data beyond what is required for handling your request. Such request should clearly state which right you wish to exercise and the reasons for it if such is required. It should also be dated and signed, and accompanied by a digitally scanned copy of your valid identity card proving your identity.

Circuit Foil will promptly inform you of having received this request. If the request proves valid, Circuit Foil shall honour it as soon as reasonably possible and at the latest thirty (30) days after having received the request.

If you have any complaint regarding the processing of your personal data by Circuit Foil, please feel free to contact Circuit Foil via the general privacy e-mail address mentioned above. You also have the right to file a complaint with the competent data protection authority.