Privacy and GDPR
Circuit Foil Data Protection Policy
This data protection policy (hereinafter: “Privacy Policy”) governs the processing of your personal data as part of your visit to our website http://www.circuitfoil.com (hereinafter: “Website”) and your communication with us via e-mail, telephone or fax and social media (hereinafter: “Social Media Channels”; eg. Facebook, LinkedIn, …).
NOTE 1: This Privacy Policy does not apply to the processing of personal data of people who choose to apply via our online job form. The processing of personal data via the job form is governed by a separate data privacy statement (Applicant Data Protection Policy).
NOTE 2: If you want information on how we process personal data via cookies, social plug-ins, pixels and other types of tracking technology, you are kindly referred to our Cookie Policy.
1. IN GENERAL
Your personal data are processed by Circuit Foil Luxembourg, 6, Salzbaach at L-9559 Wiltz, Luxembourg, Trade and Companies Register n° B93110 (hereinafter: “Circuit Foil”, “we”, “us”, “our”), which acts as Data Controller in the sense of the General Data Protection Regulation. You can contact us via e-mail at privacy@circuitfoil.com .
1.2. Any notion starting with a capital shall be defined by explicit reference in this Privacy Policy. Where possible given the context, singular words shall be interpreted as also including the plural and vice versa.
1.3. Where reference is made to certain laws or regulations, such reference shall also include any change, replacement or annulment of said laws or regulations, including any related executive decisions.
1.4. Circuit Foil reserves the right to modify, change or amend the Privacy Policy at our own discretion and from time to time. Such modification, change or amendment shall 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 privacy@circuitfoil.com. If we do not receive such an e-mail from you within three (3) business days after the changes to the Privacy Policy have been announced on our Website, you will be deemed to have accepted unambiguously all such changes.
2. TYPES OF DATA WE PROCESS
2.1. Whenever you use our Website and Social Media Channels, we collect:
• Technical information associated with the device you use, such as your IP address, browser type, geographical location and operating system;
• Information concerning your browsing behaviour, such as how long you visit, what links you click on, what pages you visit and how many times you visit a page.
2.2. When you contact us via our Website, or contact us via e-mail, telephone, fax and Social Media Channels, we collect:
- The basic identity information you provide us with, such as name, e-mail address, postal address, telephone number, the company you work for, your function;
- The content of your communication and the technical details of the communication itself , such as with whom you correspond at our end, and the date and time;
- Publicly available information of your profile on Social Media Channels;
- Any other personal data you choose to provide to us.
2.3. All of the personal data listed above, we receive directly from you. It may happen that we receive additional information about your preferences and surfing behaviour from partners such as Google, Facebook. If you require more information about the personal data these process about you and make available to others, you are kindly requested to consult their respective privacy policies :
• Google
• Facebook
3. PURPOSES FOR PROCESSING
3.1. Circuit Foil processes your personal data to provide you in a personalised and efficient way with the information, products and services you request via the Website, e-mail, telephone, fax, and Social Media Channels.
3.2. Circuit Foil processes your personal data to comply with legal obligations or to comply with any reasonable request from competent law enforcement agents or representatives, judicial authorities, governmental agencies or bodies, including competent data protection authorities.
Your personal data may be transferred upon Circuit Foil’s own initiative 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 registration with or use of the Website or other communication with us.
3.3. Circuit Foil processes your personal data to perform statistical analyses so that we may improve our Website, Social Media Channels, products and services or develop new products and services.
3.4. Circuit Foil may process your personal data for informing any third party in the context of a possible merger with, acquisition from/by or demerger by that third party, even if that third party is located outside the EU.
3.5. Circuit Foil may process your personal data for the preservation of the legitimate interests of Circuit Foil, our partners or a third party if and when your registration with or use of the Website, Social Media Channels or other communication channels can be considered (a) a violation of any applicable terms of use or the intellectual property rights or any other right of a third party, (b) a threat to the security or integrity of the Website, Social Media Channels or other communication channels, (c) a danger to the Website, Social Media Channel or other communication channels or any of Circuit Foil’s or our subcontractors’ underlying systems due to viruses, Trojan horses, spyware, malware or any other form of malicious code, or (d) in any way hateful, obscene, discriminating, racist, slanderous, spiteful, hurtful or in some other way inappropriate or illegal.
4. LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA
4.1. The processing of your personal data for the purposes outlined in clauses 3.2 is necessary to allow Circuit Foil to comply with our legal obligations.
4.2. The processing of your personal data for the purposes outlined in clauses 3.1, 3.3, 3.4 and 3.5 is necessary for the purpose of the legitimate interests of Circuit Foil, which are:
• Continuous improvements to Circuit Foil’s 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 an overall successful commercialization of our products and services.
5. RECIPIENTS
5.1. Circuit Foil does not send your personal data in an identifiable manner to any third party without your explicit permission to do so.You understand, however, that if you uses our Social Media Channels, your personal data is also processed by the social media providers.
5.2. Circuit Foil relies on third party processors to provide you the Website as well as to 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.
5.3. Circuit Foil may share your personal data with other entities within the Circuit Foil group of companies. However, we will ensure that all Circuit Foil group entities will take due care that all processing of your personal data is in line with what is set out in this Privacy Policy.
6. LOCATION AND TRANSFER
6.1. Circuit Foil processes your personal data first and foremost within the EEA. However, in order to process your personal data for the purposes outlined in clause 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 which are located outside the EEA. Each entity outside the EEA that processes your personal data shall 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
• Of a contractual arrangement between Circuit Foil and that entity. All Circuit Foil entities are parties to a contractual arrangement based on the EC’s Standard Contractual Clauses (controller-to-controller) (Commission Decision C(2004)5721).
6.2. Circuit Foil may transfer anonymised and/or aggregated data to organizations outside of 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 as well as all rights with respect to personal data you might enjoy under applicable mandatory law.
7. QUALITY ASSURANCES
7.1. Circuit Foil does it utmost best to process only those personal data which are necessary to achieve the purposes listed under clause 3.
7.2. Your personal data are only processed for as long as needed to achieve the purposes listed under clause 3 of this Privacy Policy or up until such time where you withdraw your consent for processing them. Note that withdrawal of consent may imply that you can no longer use the whole or part of the Website, Social Media Channels and other communication channels. Circuit Foil will de-identify or delete your personal data when they are no longer necessary for the purposes outlined in clause 3, 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 or deleting them.
7.3. You understand that an essential aspect of our marketing efforts pertains to making our marketing materials more relevant to you. This means that Circuit Foil builds a profile of you based on relevant characteristics as outlined in clause 2.
7.4. Circuit Foil will take the appropriate technical and organizational 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 our third party processors will only be on a need-to-know basis and subject to strict confidentiality obligations. You understand, however, that safety and security are best efforts obligations only which can never be guaranteed.
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.
8.2. You have the right to ask that any personal data pertaining to you that are inaccurate, are corrected free of charge. If a request for correction is submitted, such request shall be accompanied of proof of the flawed nature of the data for which correction is asked.
8.3. You have the right to withdraw your earlier given consent for processing your personal data, in which case clause 8.4 will apply.
8.4. You have the right to request that personal data pertaining to you be deleted if they are no longer required in light of the purposes outlined in clause 3 or if you withdraw your consent for processing them. However, you need to keep in mind that a request for deletion will be evaluated by Circuit Foil against:
• Overriding interests of the 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 and when (a) you contest the accuracy of that data, (b) the processing is illegitimate or (c) the data are no longer needed for the purposes listed under clause 3 but you need them to defend yourself in judicial proceedings.
8.5. 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 his 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.
8.6. 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.
8.7. If you wish to submit a request to exercise one or more of the rights listed above, you can send an e-mail to privacy@circuitfoil.com. An e-mail requesting to exercise a right shall 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, you may always contact Circuit Foil via the e-mail address listed in this clause. If you remain unsatisfied with Circuit Foil’s response, you are free to file a complaint with the competent data protection authority.