Privacy Policy

At Publi-CT, we take privacy and confidentiality matters very seriously. We have developed this 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 Publi-CT.

We collect personal information from you in the course of our business, including through your use of our Website, when you contact, comment or request information from us when you engage our marketing or other services or as a result of your relationship with one or more person of our staff, business partners and clients.

This Privacy Policy is issued by the Marketing Agency Publi-CT S.à r.l.-s (société à responsabilité limitée simplifié), a company established at 8 Schumanswee L-5752 Frisange, Grand Duchy of Luxembourg, and registered with the Luxembourg Trade & Companies Register under number B236550.

Any processing performed by Publi-CT is made 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.

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;

“processing” which means any act made in relation to such personal data (e.g. collecting, storing, and transferring data);

“data subjects“, “you” and “your” refer to you as individuals whose personal data are being processed by Publi-CT, or to individuals associated with you or our clients, suppliers, business partners, contacts, and any other third party of whom we collect personal data.

1. Collection of personal data

When do we collect your personal data?

We collect, store and otherwise process personal data relating to individuals having interactions with Publi-CT including through your use of our Website, for instance, when you engage our marketing consultation, advice, assistance or other services, when you provide services to us as a supplier, when you contact or request information from us, when we exchange information or interact in any way.

How do we obtain your personal data?

  • We collect information from you as part of our business acceptance process as well as information about you as necessary in the course of providing marketing services;
  • We gather information about you when you provide it to us, or interact with us directly;
  • We collect or receive information about you from other sources; we notably keep the contact details we already hold about you accurate and up to date using publically available sources;
  • We collect your personal information while monitoring our technology tools and services, including our websites and email communications sent to and from Publi-CT.

When we indirectly receive personal data relating to third party individuals, the persons providing Publi-CT with such personal data undertake to do so in compliance with the applicable data protection laws and, in particular, to inform such third party individuals of the processing performed by Publi-CT and, as the case may be, to provide them with this Privacy Policy.

Update of personal data. We will endeavor to keep the personal data in our possession or control accurate. Data subjects providing personal data are however responsible for promptly informing us of any change to their personal data.

Refusal to provide your personal data. You have the right to refuse to provide us with your personal data but you are aware that not providing us with certain personal data (e.g. data requested in the course of our business acceptance process) would, unfortunately, prevent Publi-CT from interacting with you, providing you services, entering into an agreement or maintaining any ongoing agreement with you.

2. Types of personal data processed

We aim to be transparent about what we process and why. For further information on our processing activities, please review the relevant sections below:

(i) Clients and individuals associated with clients:

– Collection: We request that our clients provide us with personal data that is necessary for us to run our business acceptance process and perform our services. We sometimes process personal data regarding clients and individuals related to clients (e.g. their customers, employees, managers, etc.) that we received from a third party or acquired from public sources.

– Types of personal data processed:

  • Identification information (such as first name, family name, date and place of birth).
  • Contact information (such as phone and fax numbers, email address, country of residence).
  • Financial information (such as identification and number of bank account, notably linked to billing).
  • Personal information provided to us by or on behalf of our clients or generated by us in the course of providing services to them.
  • References information (such as, as the case may be, your details, the general scope of our mission, the marketing services we provided you with and/or the transactions on which we assisted you.
  • Types of services received or provided.
  • Other relevant personal details (such as job title, function within a company, preferred language).
  • Any other personal data related to the provision of Publi-CT’s services to its clients.

(ii) Business contacts and prospects:

– Collection: The personal data of business contacts and prospects that are not clients of Publi-CT and do not provide services to us are stored by Publi-CT in a database and processed as described below.

Most personal data we process with respect to business contacts and prospects is information that is knowingly provided to us by such data subjects (such as when they provide a member of Publi-CT with a business card or when a contact asks us to call him or her to provide some information about Publi-CT and our services). However, in some instances, we process personal data received from a third party or accessed from public sources.

– Types of personal data processed:

  • Identification information (such as first name, family name).
  • Business contact information (such as phone and fax numbers, email address).
  • Other relevant personal details (such as job title, function within a company, preferred language).
  • Any other personal data in relation with the conduct of Publi-CT’s business.

(iii) Suppliers including individual contractors:

– Collection: We collect personal data from our suppliers and individuals related to our suppliers (e.g. contact persons) and from individual contractors.

Most of the personal data we process with respect to suppliers is information that is knowingly provided to us by them. However, in some instances, we process personal data of individuals related to suppliers.

– Types of personal data processed:

  • Identification information (such as first name, family name).
  • Business contact information (such as phone and fax numbers, email address).
  • Other relevant personal details (such as job title, function within a company, preferred language).
  • Any other personal data in relation with the management by Publi-CT of its suppliers.

(iv) Users of the Publi-CT Website:

– Collection: A number of features on our Website invite you to provide us with personal information.

Most personal data we process in respect to users of the Publi-CT Website is information that is knowingly provided to us by such data subjects (such as when they contact us to obtain some information about Publi-CT and our services).

We also collect technical information, such as information from your visits to our Website or in relation to materials and communications we send to you electronically. The collection and processing of such technical information is often made via cookies and is described in more detail in our Cookie Policy.

– Types of personal data processed:

  • IT-related information (such as record of your correspondence including e-mail address, terms of search).
  • Identification information (such as your name).
  • Contact and details information (such as e-mail address).
  • Any other personal data in relation with the operation of the Publi-CT’s Website and business.

Our Privacy Policy does not apply to information collected on any third party website that may link to or be accessible from our Website.

3. Legal basis for the processing of personal data

We will only process personal data where we have a lawful reason for doing so. The lawful basis for the processing of personal data performed by us will always be one of the following, depending on the concerned processing, nature of personal data and data subjects:

  • it is necessary for Publi-CT to take measures at your request prior to entering into an agreement or for the performance of any contractual obligations towards you;
  • it is necessary for Publi-CT to be able to comply with legal obligations (including those imposed by virtue of applicable commercial and tax laws) as well as any regulatory obligations and to respond to requests and comply with requirements from public authorities;
  • it is necessary for the establishment, exercise or defence of legal claims or proceedings;
  • it is necessary for the purposes of the legitimate interests pursued by us or by a third party, such as, for us:
    • to provide and improve our services to you and to our clients, including handling the personal information of others on behalf of our clients;
    • to provide and improve our website, including auditing and monitoring its use;
    • to provide information requested by you;
    • to promote our services
    • to manage and administer our relationship with you and our clients (e.g. for billing purposes);
  • you have given your prior consent to the processing of your personal data for us to contact you and send you commercial communications and your consent has been obtained pursuant to applicable laws.

No automated decisions will be made in relation to the personal data processed.

4. Disclosure of personal data

To achieve the above-listed purposes, in compliance and to the extent permitted under our deontological obligations, we disclose personal data to the following recipients:

  • clients;
  • external services providers (including IT services providers);
  • third parties to which we provide services;
  • professional advisors;
  • members of as well as public organizations, administrative or legal authorities and supervisory bodies, if applicable;

5. Retention

Publi-CT 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 or required under applicable laws.

6. 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 about you;
  • 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 Publi-CT’s legitimate interests;
  • receive your personal data
  • withdraw any consent given to the processing at any time to the extent that your consent justified such processing;
  • seek the restriction of the processing, for instance, when you contest the accuracy of the personal data.

We will only be able to answer favorably to any of the above requests related to the right to oppose, the right of erasure and the right of restriction if (a) it does not interfere with or contradict a legal obligation of Publi-CT (e.g. a legal obligation to keep the related personal data) or (b) any other impediment justifies that Publi-CT is not able to fulfill such requests. Publi-CT undertakes to handle each request free of charge and within a reasonable timeframe.

Publi-CT will respond to individual complaints and questions relating to privacy and will investigate and attempt to resolve all complaints.

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. The CNPD can be contacted as follows:

7. Technical and organizational security measures

Ensuring that personal data is appropriately protected from data breaches is a top priority for Publi-CT. 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.

Access to personal data is permitted to employees for the sole purpose of performing their professional duties. They are subject to a confidentiality obligation and are notably provided with training and documentation in order to improve their practical skills and knowledge on data protection issues.

8. Amendment

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

9. Contact and exercise of your rights

You can contact us for any question regarding data protection or for exercising your rights by email at: dataprotection@publi-ct.lu.