Privacy Policy

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Effective date: July 10, 2018

At MM Publishing and Media SA ("us", "we", or "our"), we take privacy and confidentiality matters very seriously. We have developed this Privacy Policy (the “Privacy Policy”) to clearly define our ongoing commitment to protecting privacy rights and to explain how we collect personal data through your use of the www.maisonmoderne.com, www.paperjam.lu, guide.paperjam.lu, club.paperjam.lu, jobs.paperjam.lu, archiduc.lu, delano.lu, jobs.delano.lu, explorator.lu websites, newsletters and mobile applications (the "Service") and how we use and disclose such personal data.

Any processing of your personal data is made in accordance with applicable data protection laws, including but not limited to, the European General Data Protection Regulation 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.

By using the Services, you acknowledge that you have been informed of this Privacy Policy and that you understand and accept its content.

Definitions

Personal Data

Personal Data means any information allowing the direct or indirect identification of an individual natural person.

Usage Data

Usage Data means data collected automatically and generated either through the use of the Services or from the Service infrastructure itself (for example, the duration of a page visit).

Cookies

Cookies are small files stored on the hard drive of your computer or in your browser memory when using our Services.

Data Controller

Data Controller means a person who (either alone or jointly) determines the purposes for which and the manner in which any Personal Data is, or is to be, processed.

For the purpose of this Privacy Policy, we are the Data Controller of your Personal Data.

Data Processors (or Service Providers)

Data Processor (or Service Provider) means any person (other than an employee of the Data Controller) who processes the Personal Data on behalf of the Data Controller.

We may use the services of various Service Providers in order to process your Personal Data more effectively.

Data Subject

Data Subject is any identified or identifiable individual who is the subject of Personal Data.

User

The User is the individual using our Services. The User corresponds to the Data Subject, who is the subject of Personal Data ("you" or "your").

Information Collection

We collect several different types of information, including Personal Data, as mean to provide and improve our Service to you.

We will endeavour to keep the Personal Data in our possession or control accurate. Data Subjects providing Personal Data are however responsible for promptly informing us of any change to their Personal Data.

You are informed that you have the right to refuse to provide us with your Personal Data, but you are aware that not providing us with some specific Personal Data (e.g. data requested for contacting us) would, unfortunately, prevent us from answering to you, or providing you with our Service, or entering into an agreement or maintaining the related ongoing agreement with you in the context of our Service.

When do we collect Personal Data?

We will notably collect Personal Data:

  • when you navigate through our websites and mobile applications and therefore when you use our Services;
  • when you log in to our Services;
  • when you attend an event;
  • when you subscribe to receive our newsletters;
  • when you apply for a position and/or sign up for job alerts;
  • when you use our e-shop and purchase products from the e-shop;
  • when you request that we contact you;
  • when you apply to become a member, speaker or sponsor;
  • when you download documents and our applications.

Important note: Most of the time we collect Personal Data directly from the Data Subject. Should you provide information, including Personal Data, on behalf of a third party individual (e.g one of your employees), you undertake to do so in compliance with applicable data protection laws and in particular, to inform this third party of such processing and to provide him/her with this Privacy Policy.

Types of Personal Data collected

Personal Data

While using our Service, we may ask you to provide us with Personal Data which may include but is not limited to:

  • Identification information such as first name and last name, place of birth, birthdate;
  • Contact information such as email address, phone number, address, postal code, city, country of residence;
  • Business related information such as company you work for or represent, role, position, country of work;
  • Your name and photograph while attending our events;
  • Hobbies and areas of interest;
  • Products purchased;
  • Information on professional experience (resume, cover letter);
  • Personal Data contained in cookies;
  • Any other type of Personal Data provided to us in the course of the Services.

Usage Data

We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through our websites, newsletters or a mobile device.

This Usage Data may include information such as your computer's Internet Protocol address (IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the location, the time spent on those pages, unique device identifiers and other diagnostic data.

When you access the Service by or through a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, location, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

Location Data

We may use and store information about your location (“Location Data”). We use this data to provide features of our Service, to improve and customise our Service.

Tracking & Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service and hold certain information.

Cookies are files with a small amount of data which may contain Personal Data or may include an anonymous, unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies such as beacons, tags, and scripts are used to collect and track information and to improve and analyse our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some parts of our Service or it will not function properly. Unless you have adjusted your browser setting so that it will refuse cookies, your system will continue to accept cookies when you direct your browser to our Service. Accepting cookies means that you permit communication between your computer and our Service as described in this section.

Examples of cookies we use:

  • Session cookies: we use Session Cookies, which last only for the duration of your visit, to operate our Service (e.g. these enable us to identify that the same person is moving from page to page with a unique identifier).
  • Preference cookies: we use Preference Cookies, which last beyond your session, to remember your preferences and various settings (e.g. these enable us to offer you an enhanced User experience when you come back to use our Service).
  • Security cookies: we use Security Cookies for security purposes (e.g. to protect your login information).
  • Advertising cookies: Advertising Cookies are used to serve you with advertisements that may be relevant to you and your interests.

Some of the above cookies are cookies from third parties. You are free to consent or not to the use of these cookies through a banner that will appear on your screen. We use:

  • Analytics: Cookies from third parties to monitor and analyse the use of our Service. Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its own advertising network.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: http://www.google.com/intl/en/policies/privacy/

  • Advertising: We may use third-party Service Providers to show advertisements to you to help support and maintain our Service.
  • Google AdSense & DoubleClick Cookie: Google, as a third-party vendor, uses cookies to serve ads on our Service. Google's use of the DoubleClick Cookie enables it and its partners to serve ads to our users based on their visit to our Service or other websites on the Internet.

You may adapt the use of the DoubleClick Cookie for interest-based advertising by visiting the Google Ads Settings web page: http://www.google.com/ads/preferences/

We may also use beacons  [AR4] when providing our Services to you. Pages of our Service may contain electronic images known as web beacons (also referred to as single-pixel gifs). Web beacons enable us to collect certain information in relation to Users of our Service including, for example, the number of Users accessing each webpage, traffic data, location data, logs and other communication data, information in relation to resources access, and information about User computer and Internet connection (including IP addresses, operating systems and browser type). Web beacons are only used to track opening rates from our newsletters.

Purposes of the processing

MM Publishing and Media SA uses the collected Personal Data on the basis of one or more of the following purposes:

  • The processing is necessary for the performance of a contract or for entering into a contract with you;
  • The processing is necessary for us to comply with a legal obligation, for instance to allow us to comply with applicable commercial law and any regulatory obligations and to allow us to respond to requests and comply with requirements from public authorities;
  • The processing is necessary for our or a third party’s legitimate interests, for example, (i) in the context of the Services: to provide and maintain our Service, to answer any queries from you or provide requested Service, to allow you to participate in interactive features of our Service when you choose to do so, to notify you about changes to our Service, to provide customer support, to monitor the usage of our Service and gather analysis or valuable information so that we can improve our Service in accordance with applicable laws, to detect, prevent and address technical issues, to provide you with news, newsletters, special offers and general information about other goods, services and events which we offer in accordance with applicable laws, to present our Service and their contents in a suitable and effective manner for you, to enforce our policies and other agreements; (ii) outside the context of the Service: to manage our relationships with our suppliers, services provider and subcontractors as well as to prevent fraud, manage litigation and to protect the rights, property, or safety of MM Publishing and Media SA and their affiliates;
  • You have given your prior consent, for example, to receive commercial communications from us where such consent is required, or to receive third parties or for us to use third party cookies.

We may use your Personal Data to contact you at your request, or via newsletters, marketing, sales, events or promotional materials and other information that may be of interest to you in compliance with applicable laws.  Regarding commercial communications we send to you when your consent is not legally required, you may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send, or by contacting us directly. We may use your photograph when attending our events within our newsletters, websites or/and print publications.

No automated decisions will be made in relation to the Personal Data we process.

Retention of Personal Data

MM Publishing and Media SA will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your Personal Data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

MM Publishing and Media SA will also retain Usage Data for internal analysis purposes, and in compliance with applicable data protection laws when Usage Data relate to Personal Data. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

Disclosure of Personal Data

To achieve the above purposes, we may disclose Personal Data to the following recipients: other entities members of MM Publishing and Media SA, our commercial partners, clients, subcontractors, external services providers, professional advisors, purchasers or sellers of our assets (if any), as well as public organizations, administrative or legal authorities and supervisory bodies if applicable.

Transfer of Personal Data

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

When the recipients of transfers of Personal Data are located outside the territory of the European Economic Area in countries that do not offer a level of protection equivalent to the one granted in the European Union, we undertake that any Personal Data transfer to such recipients will, depending on the nature of the transfer:

  • be covered by appropriate safeguards such as standard contractual clauses approved by the European Commission, in which case you may obtain a copy of such safeguards by contacting us; or
  • be otherwise authorised under data protection laws, as the case may be, as such transfer is necessary for the performance or execution of a contract concluded in your interest or for the establishment, exercise or defence of legal claims or for the performance of a contract between you and us.

MM Publishing and Media SA will take all steps reasonably necessary to ensure that your Personal Data is treated securely and in accordance with this Privacy Policy and applicable data protection laws, and that no transfer of your Personal Data to a recipient will take place unless there are adequate security controls in place, including the security of your Personal Data.

Security of Personal Data

The security of your Personal Data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

The security of your Personal Data also means that we undertake to use all our best efforts to protect it from data breaches. We implement adequate technical and organizational security measures, such as, depending on the equipment, password protection, physical locks, etc., to ensure a level of security appropriate to the risks represented by the processing and the nature of the Personal Data to be protected.

Access to Personal Data is permitted to our employees for the sole purpose of performing their professional duties. They are subject to a confidential obligation and are notably provided with training and documentation in order to improve their practical skills and knowledges on data protection issues.

Your Rights

In relation to your Personal Data, you have the right to:

  • access the Personal Data held about you and receive additional information about how it is processed;
  • rectify or complete any inaccurate or incomplete Personal Data;
  • seek the erasure of your Personal Data when its processing is no longer necessary for the purposes described above, when the processing is not or no longer lawful for any reasons, when you have withdrawn your consent to the processing according to applicable laws, when the erasure is necessary to comply with applicable laws or when you object to the processing in the absence of any overriding legitimate ground for such processing;
  • object, on grounds relating to your particular situation, to any processing based on our legitimate interest;
  • receive your Personal Data and transmit it to another Data Controller to the extent that the legitimacy of the processing lies on contractual performance and is carried out by automated means;
  • withdraw any consent given to the processing at any time to the extent that your consent justified such processing;
  • seek the restriction of the processing, for instance, when you contest the accuracy of the Personal Data or when the processing is not or no longer compliant with the exception of storage, only processed in specific cases (e.g. for the establishment, exercise or defence of our legal claims).

We will respond to individual complaints and questions relating to privacy and will investigate and attempt to resolve all complaints. We will only be able to answer favourably to any of the above requests related to the right to oppose, right of erasure and right of restriction provided that it does not interfere with or contradict a legal obligation of us (e.g. legal obligation to keep the related Personal Data) or due to any other impediment that would justify that we would not be able to grant such requests. We undertake to handle each request free of charge and within a reasonable timeframe (in any case no longer than 1 month).

You may also lodge a complaint with the data protection authority in Luxembourg, the Commission Nationale pour la Protection des Données (the “CNPD”), or with your local data protection authority if you do not reside in Luxembourg. The CNPD can be contacted as follows:

  • Telephone: (+352) 26 10 60 – 1
  • Website: https://cnpd.public.lu/en.html
  • Web-form: https://cnpd.public.lu/en/particuliers/faire-valoir/formulaire-plainte.html
  • Address: 1, avenue du Rock’n’Roll, L-4361 Esch-sur-Alzette, Luxembourg

Please note that we will ask you to verify your identity before responding to such requests. You are informed that if you do not allow us to verify your identity by communicating the required elements (e.g. official ID document) for security purposes, we would unfortunately not be able to respond to your requests.

Service Providers

We may employ third-party companies and individuals to facilitate our Service ("Service Providers"), to provide the Service on our behalf, to perform Service-related tasks or to assist us in analysing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose, and as described in the above sections on “Transfer of Personal Data” and “Disclosure of Personal Data”.

Payments

We may provide paid products and/or services within the Service. In that case, we use third-party services for payment processing (e.g. payment processors).

We will not store or collect your payment card details. That information is provided directly by you to our third-party payment processors whose use of your Personal Data is governed by their own Privacy Policy which we invite you to consult when processing a purchase. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

The payment processors we work with are:

Links to other sites

Our Service may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

Children's privacy

Our Service does not address anyone under the age of 18 ("Children").

We do not knowingly collect Personal Data from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children have provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from Children without verification of parental consent, we take steps to remove that information from our servers.

Changes to this Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Service prior to the change becoming effective and update the "effective date" at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page. Your continued use of the Service is deemed to be an acceptance of such changes.

Contact Us

We have appointed a Data Protection Officer in order to manage and monitor our compliance with data protection obligations. You may contact our Data Protection Officer for any question or queries you may have regarding this Privacy Policy, by email at: privacy@maisonmoderne.com.

You may also contact us at the following contact details:

Privacy Policy of http://maisonmoderne.com