This privacy policy (designated the “Privacy Policy”) governs the manner in which Steinergy S. A., a Luxembourgish company with registered office at 4 Square Patton, L-8443 Steinfort, GRAND DUCHY OF LUXEMBOURG, registered with the Luxembourg Trade and Companies Registry under number B114799 or any of its affiliated companies (together designated “Steinergy”) collects, uses, maintains and discloses information collected from clients and/or users (designated each, a "User" or “Users”) of its websites, mobile applications or any other services (the "Services").
Steinergy acknowledges and undertakes to comply with the laws and regulations governing the processing of personal data, including, but not limited to, the Regulation (EU) 2016/679 of the European Parliament and of the Council 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 (designated “GDPR”) and any other national applicable laws or regulations governing the processing of any personal data.
Steinergy acts as data controller and has appointed a data protection officer.
The data protection officer appointed by Steinergy shall be contacted by using the following information:
Address:
Steinergy S.A., to the attention of the Data Protection Officer
2, Domaine du Schlassgoard
L-4327 Esch-sur-Alzette
Phone: (+352) 2737-1
Email: dpo@steinergy.lu
Steinergy may collect personal identification information from Users in a variety of ways, including, but not limited to, when Users visit Steinergy websites, register on such websites, fill out a form, sign a contract, purchase a product and in connection with other activities, applications and Services proposed by Steinergy. Users may be asked for, as appropriate, name, date of birth, email address, mailing address, phone number, etc. In the framework of certain Services, Steinergy may also collect data relating to energy consumption of the Users in order to benefit from such particular Services.
Steinergy may collect non-personal identification information about Users whenever they use an Steinergy website or application or other online service. Non-personal identification information may include technical information about Users means of connection, such as the operating system and the Internet service provider utilized, geographical information such as country of origin, behavioural information such as time spent on the website, as well as further non-personal analytical data to improve customer experience, products and services.
Each User recognizes and accepts that the performance of the Services may depend on the collection and processing of personal identification information and non-personal identification information.
Steinergy may use « cookies » to improve the User’s experience in regard of the Services. In that case, the User’s Internet navigator places cookies on his hard drive to gather a certain set of information used to customize the navigation in the framework of the Services, thus enabling certain unique functionalities. For more information on how we use cookies and the cookie options we offer please see our Cookie Policy.
Principally, personal and non-personal identification information is used to provide the Users with the Services and to insure a full efficiency of the Services they have registered for or they requested in any other manner.
In this framework, Steinergy may collect and use Users’ personal and non-personal identification information for the following purposes:
Steinergy adopts appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of Users’ personal identification information within the limits of Steinergy’ role with respect to the relevant Services (as certain specific services might be rendered by third parties).
Steinergy does not sell, trade, or otherwise transfer to third parties Users’ personal identification information. However each User accepts that its personal identification information can be transmitted to website hosting and editing partners and other sub-contractors who assist Steinergy in providing the Services, conducting its business, or servicing the User, so long as those sub-contractors undertake to process the information only according to Steinergy ’ instructions and to comply with the applicable law regarding the protection of personal identification information. Steinergy may also release User’s personal identification information when it believes that such release is necessary to comply with the law, enforce its websites’ general terms of use, or protect its or others' rights, property, or safety.
However, Users' non-personal identification information may be provided to third parties for marketing, advertising, or other uses.
Steinergy has the discretion to update this Privacy Policy at any time. Steinergy will therefore revise the “last update date” at the bottom of this page. Steinergy encourages Users to frequently check this page for any changes. Users acknowledge and agree that it is their responsibility to review this Privacy Policy periodically and become aware of modifications.
Steinergy takes all reasonable measures to ensure that your personal data are processed for the minimum period necessary for the purposes set out in this Privacy Policy. The criteria for determining the duration for which we will retain your personal data in connection with the Services are as follows:
Steinergy undertakes to delete or to anonymise your personal data upon expiry of the retention period as described above.
Steinergy has implemented appropriate technical and organizational security measures designed to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of Processing, in accordance with applicable law.
You are responsible for ensuring that any personal data that you send to us are sent securely.
Steinergy does not transfer personal data to any third country nor to any international organisation, except as the case may be on the basis of:
We take reasonable measures:
Each User benefits under data protection law from a right of access, modification and opposition to the processing of its personal data, a right to erasure and a right to portability of its personal data by sending an email to mail@steinergy.lu. Those rights may only be exercised within the limits of any contractual or legal obligation. Each User has also a right to lodge a complaint with the Luxembourg supervisory authority, namely the Commission nationale pour la protection des données (https://cnpd.public.lu/fr.html).
By using the Services, Users confirm their acceptance of this Privacy Policy. If a User does not agree with this Privacy Policy, Steinergy recommends to such User that he shall not use the Services. The continued use of the Services following the posting of changes to this Privacy Policy will be deemed as an acceptance of those changes.
This Privacy Policy is applicable from 25th May 2018.
