Latest update 30 August 2018.
We, Société Financière des Caoutchouc S.A. (Socfin), undertake to protect the privacy of the information that is entrusted to us. In particular, we undertake to ensure appropriate protection and use of personal data (i.e. data by which an individual may be directly or indirectly identified, the Personal Data) which is collected via our website www.socfin.com.
The Data Protection Legislation means Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 (the GDPR), as well as any other applicable laws, regulations and sector recommendations containing rules for the protection of individuals with regard to the processing of Personal Data, as such legislation and guidance may be complemented, amended, replaced or repealed from time to time.
1. DATA CONTROLLER AND CONTACT
Our head office is located at 4, Avenue Guillaume, L-1650 Luxembourg and we are registered with the Trade and Companies Register of Luxembourg under number B5937.
If you have questions or comments or you wish to exercise your rights, you can contact our head office at the following address: firstname.lastname@example.org.
2. CATEGORIES OF PERSONAL DATA THAT WE PROCESS
We receive and collect Personal Data directly from you, or by the use of automated technologies when you use and interact with our website.
In particular, the Personal Data concerning you, and which we process, may include:
- Personal Data that you provide by completing the contact form on our website (for example, your address and country of residence, identification data such as your name, status, email address, telephone number and information related to your request);
- if you contact us by email or telephone, the recording of these exchanges;
- server logs, including IP addresses;
- your Curriculum Vitae, application and/or letter of recommendation when you respond to a job offering; and
- all other information communicated by you.
3. FOR WHICH PURPOSES DO WE PROCESS YOUR PERSONAL DATA?
We may process your Personal Data:
3.1 For the purposes that are in our or a third party’s legitimate interests, for example:
- to contact us so that we can analyse and respond to your requests;
- to help us to manage, evaluate and improve our activities and services;
- to send you updates and announcements regarding our activity;
- to establish statistics, analyse trends and perform commercial analyses;
- to resolve bugs, to improve the performance of the website and identify the cause of a breakdown or the perpetrator of an intrusion;
- for the establishment, exercise and defence of legal claims;
- to ensure the security and continuity of our IT systems; and
- in connection with any business reorganisation, transfer, sale, disposal, merger or acquisition of our activities.
3.2 For the purposes of compliance with statutory obligations
We may process your Personal Data when this is necessary to comply with a legal or regulatory obligation to which we are subject, notably when responding to a request from the government or authorities as part of an investigation.
3.3 On the basis of your consent
Providing that you have given your consent to the processing of your Personal Data, this consent will serve as a legal basis for the processing related to it.
This includes the consent that you may have given for being contacted concerning publications and statements, including via newsletters.
This consent may be withdrawn at any time by contacting us at the contact details mentioned above, without affecting the legality of the processing based upon the consent before it is withdrawn.
4. DISCLOSURE OF YOUR PERSONAL DATA TO THIRD PARTIES?
The following recipients may receive your Personal Data:
- other entities of the Socfin Group;
- service providers, including, but not limited to, IT or website-management services providers, and financial, tax or legal advisers who process your data on our instructions;
- governmental, judicial or supervisory authorities;
- third parties involved in the management of Socfin’s activities during a merger, sale or acquisition of a company or an activity in which Socfin or another entity of the Socfin Group is involved; and
- any competent administration, regulatory authority or other parties as required by the law.
5. ARE YOUR PERSONAL DATA TRANSFERRED OUTSIDE OF THE EUROPEAN ECONOMIC AREA?
When this proves necessary for the purposes listed above, Socfin may have to transfer your Personal Data to countries located within and outside of the European Economic Area (EEA).
Personal Data may be transferred to the following countries outside of the EEA: Switzerland, Sierra Leone, Liberia, Ivory Coast, Ghana, Nigeria, Cameroon, Democratic Republic of Congo, Sao Tomé and Principe, Cambodia and Indonesia.
Personal Data may be transferred to a country outside the EEA based on the fact that the European Commission has decided that these countries have an appropriate level of protection (such as, for example, Switzerland).
Certain countries in which recipients and data processors may be located and to which Personal Data may be transferred may, however, not provide the same level of protection of Personal Data as that provided in the EEA. Personal Data will not be transferred to countries outside the EEA under circumstances other than based on your explicit consent collected in a manner organised by article 49(1) of the GDPR.
A "cookie" is a small file that websites put on your computer's disk, which enables a website to remember you.
You may choose whether or not to accept cookies, notably by configuring your browser to block some or all cookies. However, if you do not accept cookies, you might not be able to take full advantage of the functionalities of our website.
Technical Cookies that are strictly necessary to the functioning of our website cannot be refused.
7. HOW LONG DO WE RETAIN YOUR PERSONAL DATA?
Retention periods for your Personal Data are based on our commercial requirements and legal obligations. We may retain:
- all Personal Data that you have communicated to us through a request (such as by email or telephone) until we have responded to it, or until the end of our exchanges and subsequently for a period of 10 years after the end of the financial year during which the exchanges took place;
- data collected via cookies up to six (6) months after your last use of the website.
We may also retain your Personal Data, other than data collected via cookies, for three (3) years for statistical purposes.
8. ARE YOU OBLIGED TO PROVIDE YOUR PERSONAL DATA?
In the context of our activity and the functioning of our website, you only need to provide us with the Personal Data which is necessary to respond to your requests, or necessary so that our website functions normally.
However, we draw your attention to the fact that without some of this Personal Data (notably the technical cookies necessary to be able to browse the website), we will not be able to correctly respond to your requests, or certain parts of the website may become inaccessible.
9. TO WHAT EXTENT DO WE USE AUTOMATED DECISIONS MAKING OR PROFILING?
Generally, we do not use automated decision-making or profiling in our relationship with you.
If we had to use such processing in a specific situation, and to the extent that we may be legally required to do so, we would inform you of this separately.
10. WHAT ARE YOUR RIGHTS?
10.1 You have the right to information, rectification, deletion and restriction of processing
You may request to obtain at no costs, within reasonable intervals, and in a timely manner, the communication of your Personal Data being processed as well as all information about the origin of such Personal Data.
You also have the right to rectify any inaccurate Personal Data that we hold concerning you.
In the case where (i) the accuracy of the Personal Data is disputed, (ii) the processing is unlawful, or (iii) if you object to the processing of your Personal Data, you may request the restriction of processing of this Personal Data. This means that the Personal Data, with the exception of storage, will only be processed with or for the establishment, exercise or defence of rights, for the protection of rights of another individual or legal entity, or for reasons of important public interest of the European Union or of a member state of the European Union. In case a processing is restricted, you will be informed before the restriction of the processing is lifted.
You may request the deletion of Personal Data concerning you, without undue delay, when the use or other processing of this Personal Data is no longer necessary for the purposes described above, and notably when consent relating to a specific processing has been withdrawn or when the processing is illegal, or is not or no longer legal for other reasons.
10.2 Your right to object to processing
You may object to the processing of your Personal Data, which is based on our legitimate interest or that of a third party. In such a case, we will no longer process your Personal Data, unless we have legitimate and compelling reasons for this processing which override your interests, rights and freedoms, or for the establishment, exercise or defence of legal claims.
You also have the right to object, at any time, to the processing of your Personal Data for marketing purposes.
Your right of objection is not related to any formality other than requesting it at the above email address.
10.3 Right to withdraw your consent
If the processing of Personal Data is based on consent, you have the right to withdraw your consent at any time, without this affecting the legality of the processing based on the consent before its withdrawal. The withdrawal effects only subsequent processing.
10.4 Right to data portability
When the processing of data is based on consent or legitimate interests and the processing is done by technical means, you also have the right to data portability for your Personal Data that you have provided to us – this means that you can obtain a copy of your Personal Data in a commonly used format, so that you can manage and send it to another data controller.
10.5 Right to lodge a complaint
If you wish to lodge a complaint about how we process your Personal Data, please contact us in the first instance using the contact details provided above.
We will endeavour to process your request as soon as possible, without prejudice to your right to make a complaint to the Luxembourg data protection authority (the Commission nationale pour la protection des données) or another European data-protection authority (such as in your country of residence) if you have doubts about the processing of your Personal Data.
11. LINKS TO THIRD-PARTY INTERNET SITES
Our website may contain links to third-party Internet sites.
We invite you to read the privacy policies of these third-party websites to find out about the processing of data.