Privacy Policy

At JCS s.àr.l., one of our top priorities is making sure that the information we have about you is protected and secure. We value our relationship with you and work hard to preserve your privacy and ensure that your preferences are honoured. At the same time, the very nature of our relationship may result in us processing certain types of information about you or your end users (customers or employees). We explain how we use personal data information in this privacy policy statement.

The Luxembourg law of 2nd august 2002 and the regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR) governs JCS s.àr.l.’ processing of personal identifying information for the protection of persons in the context of treating personal data.

Collection of personal data

We collect information that:

you give us on applications, surveys, registration forms…;

  • you give us during meetings where there is an exchange of business cards;
  • you give us when you make a purchase (product, services or training);
  • you give us for human resources purposes during application processes;

We process this Information:

  • to ensure requested services and products delivery;
  • to execute a sales contract;
  • to optimaly organize a meeting;
  • to inform you about news from JCS s.àr.l., new technologies, new services…
  • to process transactions (purchase/accounting data);
  • to respond to your queries and applications.

Specific information on privacy for professional customers and their end users

JCS s.àr.l. as data controller

JCS s.àr.l. may act as a data controller for the customer’s contact persons details which would be collected by JCS s.àr.l..

This data is used by JCS s.àr.l. for delivering the requested services, for billing, for dispute management, for detecting fraud and infringements against JCS s.àr.l., its employees, customers or suppliers, for improving product and service quality, for internal reporting purposes, for the planning and organization of infrastructure and recording in our ticketing tool, for market research and to invite the customer or its end users to test products and services, , services and offers more relevant to the customer or its users. In addition, certain personal data may be processed due to a JCS s.àr.l. legitimate interest, such as promoting its products and services. Some personal data may also be processed as JCS s.àr.l. has a legal obligation to do so, e.g. at the request of the competent authorities.

JCS s.àr.l. delegates to professional customers the obligation to provide the following important information to its end users:

  • information about the processing of personal data of end users by JCS s.àr.l., which acts as a data controller for the purposes mentioned in the paragraph above;
  • the way in which users can exercise their rights regarding their personal data, as described further in this chapter;
  • the retention period of the personal data collected by JCS s.àr.l.: personal data is stored for a maximum of 10 years after the contract with the customer ends.

JCS s.àr.l. as data processor

JCS s.àr.l. acts as a data processor whenever it processes personal data at the customer’s request. This is the case for personal data:

  • which the customer stores in JCS s.àr.l.’ data centres or cloud (e.g. hosting, outsourcing, maintenance and support, housing, and other Cloud services);
  • which the customer enters in a tool made available by JCS s.àr.l.;
  • which the customer entrusts to JCS s.àr.l. for the purpose of configuring the service.

Other data processors or “sub-processors”

When JCS s.àr.l. acts as a data processor for personal data of the customer or its end users, it can be assisted by sub-processors.  JCS s.àr.l. remains liable to the customer for the protection of the personal data of the customer’s end users.

Rights of the end users of professional customers regarding their personal data

The end users of professional customers have the right to access, rectify and delete their personal data
and must go first to JCS s.àr.l.’ professional customer to exercise these rights.

JCS s.àr.l.’ professional customer will then contact JCS s.àr.l. for such request.

Online specific statement

JCS s.àr.l. is committed to taking reasonable steps to protect the individual identifying information that you provide to us.

Collection of data for statistics and reporting

When you link up to the websites hosted by JCS s.àr.l. website to view information or to download files, we automatically collect the following data:  type of domain name used to gain access to the Internet (f.e.com, .org), IP address attributed during the connection, date and time of access to the website, duration of website/page visit, browser used, the operating system or platform installed on your personal computer or the access device used, search engine and meta tags used to track the website on the web, type and nature of files or information that has been downloaded. These log files are intended to map the number of visitors on various sections of our website and to continuously improve the content of the website.

Links to external websites

Hosted websites by JCS s.àr.l. may contain links to external websites. JCS s.àr.l. is not responsible for the content and the privacy practices of other websites and encourages you to examine each website’s privacy policy and disclaimers in order to make your own decisions regarding the accuracy, reliability and correctness of material and information found there. Applications, surveys, registration forms collecting certain information in order to be able to provide all requested services. Compulsory indications will be expressly highlighted in applications, surveys, registration forms…

Processing of information collected

Your personal data will be gathered and processed in accordance with any applicable data privacy laws:

  • the Luxembourg Law of August 2nd, 2002 on the Protection of Persons regarding the Processing of Personal Data;
  • the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons regarding the processing of personal data and on the free movement of such data (GDPR).

To the extent permitted by applicable laws, we share information between JCS s.àr.l.’ affiliates in Luxembourg. To respond to your enquiries, it can happen that we share personal information with our partners. This is done when they perform services on our behalf.

Thereby, your collected personal information will be stored and processed in Luxembourg and may be transferred to JCS s.àr.l. international suppliers (for example for the performance of requested services on behalf of JCS s.àr.l.).

Personal information may also be disclosed by JCS s.àr.l. if required by a legal provision or judicial or administrative decision.

How we protect information

We strive to protect your data and safeguard it from unauthorized individuals. We commit ourselves to ISO certifications what expresses our responsibility on processing data in a safe and secure way.

We have taken technical and organizational measures to protect databases on which your data is kept, against unauthorized access, unauthorized use, theft or loss. Our security measures are regularly evaluated and adapted so that we can continue to provide a high level of protection.

Rights to access, rectify and delete (“Right to be forgotten”)

You have the right to access, rectify, and delete your personal data. You have the right to obtain from the controller restriction of processing (when one of the GDPR conditions applies) and the right to data portability for the data you provided to JCS s.àr.l.

To do so, send a request (dated and signed) with a copy of your identity card to our Legal Department, (JCS s.àr.l. / (DPO), 16 rue Paul Faber L-6785 GREVENMACHER) or to dpo@jcs.lu.

However, it is important to note that a refusal to provide personal data or the exercise of such rights may result in the impossibility to carry out the required services for JCS s.àr.l.

Contact details of the JCS s.àr.l. data protection officer

If you have questions about JCS s.àr.l.’ privacy policy, you can contact our Legal Department:

Contact details:

E-mail: dpo@jcs.lu

Address: JCS s.àr.l. / (DPO), 16 rue Paul Faber L-6785 GREVENMACHER

Data protection authority

End users have the right to lodge a complaint with the data protection authority. For more information, see www.cnpd.lu.

Cookie policy

What are cookies?

A cookie is a text file that is installed in the browser of your computer or mobile device by a website’s server when you consult a website. The cookie contains a unique code which makes it possible for your browser to be recognized when you visit the website (“session” cookies) or during subsequent, repeated visits (“permanent” cookies). Cookies can be installed by the server of the website you visit or by partners of that website. A website’s server can only read the cookies it has installed itself and has no access to other information found in your computer or mobile device. Cookies are stored in the folder of your browser on your computer or mobile device. A cookie usually consists of the name of the server that placed the cookie, an expiry date, and a unique number code. Cookies generally make the interaction between the visitor and the website faster and easier, and help the visitor navigate between the different parts of a website. Cookies can also be used to make the content or advertisement on a website more relevant for the visitor and can be adapted to his personal taste and needs. Cookies can be used by websites hosted by JCS s.àr.l. JCS s.àr.l. is not responsible for cookies used by the customers websites.

Different kinds of cookies:

1. Necessary cookies

These cookies are indispensable for visiting our websites and using certain parts of the websites. For instance, they allow you to navigate between the different parts of the website and fill in forms. If you refuse these cookies, certain parts of the website will not work, or will not work optimally.

2. Functional cookies

Functional cookies are cookies that make it easier for our websites to work, make them more pleasant for visitors, and ensure that you have a more personalized browsing experience. For example, these cookies can remember your language choice or whether you were already asked to participate in a survey so that you are not asked again the next time you visit the website.

3. Performance cookies

Performance cookies can be used to obtain information about visitors’ use of websites, improve the content of the websites, adapt them to the wishes of visitors, and make them more user-friendly. For instance, there is a cookie that counts the number of unique visitors, and a cookie that keeps track of the most popular pages. Managing cookies. You can refuse the installation of cookies via your browser settings. You can also remove cookies already installed on your computer or mobile device at any time.