Privacy and cookies
“personal data” which means any information allowing the direct or indirect identification of an individual natural person;
“processing” which means any act made in relation to such data (e.g. collecting, storing, and transferring data);
“data subjects”, “you” and “your” refer to any individual using our website.
1. COLLECTION OF PERSONAL DATA
When do we collect personal data? We will only collect the following personal data:
IT-related information. Such as your IP address, the name of your internet service provider, the operating system and the browser you used, the date and duration of your visit, the name(s) of the visited page(s).
We use the following types of cookies on our website:
- Necessary cookies. Which help make our website usable by enabling basic functions like page navigation and access to secure areas of our website (e.g. these preserve your user states across page requests or store your user’s cookie consent state for the website);
- Statistics cookies. Which help us to understand how you interact with the website (e.g. these enable us to identify that the same person is moving from page to page and also enable us to offer you an enhanced user experience when you return to our website). We store and collect a unique ID to track your session from page to page via session cookies.
- Analytics third parties cookies:
This site uses Google Analytics, a web analytics service provided by Google, Inc. Google Analytics sets a cookie in order to evaluate our use of our website and compile reports on user activity.
Google stores the information collected by the cookie on servers in the United States. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google.
- Third parties functionality cookies
This site uses Vimeo to embed videos.
- Visitor’s cookie preference (collect of consent)
This is used to store the visitor’s cookies consent preference (agree or disagree). No third party cookies are stored on the visitor’s device until the visitor gives their consent. Stored for 1 year
You are free to consent or not to the use of these third party cookies through a banner that will appear on your screen.
For more information on the privacy practices of the above third parties, please refer to the respective privacy policies of these third parties accessible on their websites.
2. LEGAL BASIS AND PURPOSES OF THE PROCESSING
In most cases, the above personal data will be processed for at least one of the following:
- it is necessary for the purposes of the legitimate interest pursued by us or by a third party, in the context of the website such as to provide you with information about ABHH and its services that might be of interest to you, to make statistics, to present our website and its content in a suitable and effective manner for you, to use the cookies in relation to our website;
- you have given prior consent to the processing of your personal data and your consent has been obtained pursuant to applicable laws, such as to use third party cookies.
No automated decisions will be made in relation to the personal data processed.
3. DISCLOSURE OF PERSONAL DATA
To achieve the above purposes, we may disclose the personal data we hold to the following recipients: other entities members of ABHH Group, external services providers, professional advisors, purchasers or sellers of our assets and entities linked to ABHH if any, as well as public organisations, administrative or legal authorities and supervisory bodies if applicable.
Transfer of personal data. You are informed that certain recipients may be 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. 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 by contacting us; or
- be otherwise authorised under data protection law, 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.
ABHH will store your personal data only for as long as necessary for the relevant processing activity to be completed and/or for the retention period permitted under applicable law.
5. 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 ABHH’s 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; and
- 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 ABHH’s legal claims).
ABHH 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 ABHH (e.g. legal obligation to keep the related personal data) or due to any other impediment that would justify that ABHH would not be able to grant such requests. ABHH undertakes 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, a list of which is available at https://edpb.europa.eu/about-edpb/board/members_en. The CNPD can be contacted as follows:
- Telephone: (+352) 26 10 60 – 1
- Website: https://cnpd.public.lu/en.html
- Address: 1, avenue du Rock’n’Roll, L-4361 Esch-sur-Alzette, Luxembourg
6. TECHNICAL AND ORGANIZATIONAL SECURITY MEASURES
Ensuring that personal data is appropriately protected from data breaches is a top priority for ABHH. 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.
You should be aware, however, that communications over the Internet (including e-mails to ABHH) are not 100% secure and we cannot guarantee absolute security.
Our website may contain links to other websites that are operated by third parties. We cannot be responsible for the privacy practices or content of those other websites.
Access to personal data is permitted to 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 knowledge on data protection issues.
8. CONTACT AND EXERCISE OF YOUR RIGHTS
Last updated: June 2021