Privacy and cookies

At ABHH, we take privacy and confidentiality matters very seriously. We have prepared this website Privacy Policy (the “Privacy Policy”) to clearly define our ongoing commitment to protecting privacy rights and to explain how we collect, use and disclose personal data when you interact with ABHH in the context of our website www.abhh.lu.

This Privacy Policy is issued by ABH Holdings S.A. (hereinafter “ABHH”, “us” or “our”), a public limited liability company (société anonyme) formed under the laws of Luxembourg with registered office at 3, Boulevard du Prince Henri, L-1724 Luxembourg, Grand-Duchy of Luxembourg, registered within the Registre de Commerce et des Sociétés in Luxembourg under the number B151018.

In the context of this Privacy Policy, ABHH acts as data controller (i.e. the organisation which determines why and how to process personal data), within the meaning of and 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 our website, you acknowledge that you have been informed of this Privacy Policy and that you understand and accept its content. If you do not accept the content of this Privacy Policy, please contact us or stop using our website immediately.

In this Privacy Policy we use the following terms within the meaning of applicable data protection laws:

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).

Cookies. A cookie is a small text file stored on the hard drive of your computer or in your browser memory when you visit our website. This file asks permission to be placed on your device. Once you agree (or your browser agrees automatically if it is set it up in that way), this file is added in your device. ABHH uses cookies that may contain personal data as the case may be. Use of cookies helps us to make our website usable, as well as to improve our website and to deliver a better and more personalized service by enabling us to, for example: (i) make statistics, estimate our audience size and usage patterns; (ii) store information about your preferences, allowing us to customize our website according to your individual interests; and (iii) recognize you when you return to our website and know what parts of the website you visit, your preferences and what is most relevant to you.

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.

Most browsers are initially set up to accept cookies. However, you can reset your browser to refuse all cookies or indicate when a cookie is being sent. You will need to consult the help area of your browser application for instructions. If you choose to disable your cookies setting or refuse to accept a cookie, some parts of our website will not function properly or may be considerably slower. 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 website. Accepting cookies means that you permit communication between your computer and our website as described in this section.

We also use cookies implemented by third parties such as:

  • Analytics third parties cookies:

Name

Explanation

_ga,

_gat

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.

  • Visitor’s cookie preference (collect of consent)

Name

Explanation

cookies_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.

  1. 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.

  1. 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.
  1. RETENTION

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.

  1. 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

- 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

  1. 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.

  1. AMENDMENT

ABHH reserves the right to change, supplement and/or amend this Privacy Policy at any time. In such case, notification will be given to you by methods chosen by us and allowed under applicable law.

  1. CONTACT AND EXERCISE OF YOUR RIGHTS

For any question or for exercising your rights in relation to this Privacy Policy, please use the following email address: contact@abhh.lu

 

Last updated October 2019