This Privacy Notice explains how FINOLOGEE (“FINOLOGEE”, “we”, “us” or “our”) collects, uses, shares and otherwise processes your Personal Data in accordance with applicable data privacy laws and regulations, which include the General Data Protection Regulation 2016/679 (“GDPR”) which is applicable as of 25 May 2018.

Your privacy is important to us. The purpose of this Privacy Notice is to inform you about the information FINOLOGEE may gather about you, how FINOLOGEE may use that information, whether FINOLOGEE discloses it to anyone, and the choices you have regarding our use of the information FINOLOGEE collects.

1. Personal data we collect about you

When using the term “Personal Data” in our Privacy Notice, we mean information that relates to you and allows us to identify you, either directly or in combination with other information that we may hold, as defined by the GDPR.

We will process your Personal Data if and to the extent applicable law provides a lawful basis for us to do so. We will therefore process your Personal Data only:

  • If you have consented to us doing so, or
  • If we need it to perform the contract we have entered into with you; or
  • If we need it to comply with a legal obligation; or
  • If we (or a third party) have a legitimate interest which is not overridden by your interests or fundamental rights and freedoms.

We may collect personal information through your use of our website, when you contact or request information from us or when you subscribe to our newsletter (if this feature is provided). The data category collected is the following:

  • Personal identification information: name and surname, postal and e-mail address, phone number, content or messages you send to us or provide otherwise directly to us such as inquiries, questions, comments, answers to questions

2. How we use information

We may use data we obtain for purposes relating to our website and services, including (a) providing the website and services to you, (b) raising queries with you, and responding to issues you may raise, whether relating to our services or otherwise, (c) processing job applications and (d) generating anonymized statistics and analysing anonymized statistical usage data of our web site. We may use the following third-party service providers named below to process and store your data:

  • WordPress, which we use to host and manage the content of this website. Your data may be stored through WordPress.org’s data storage, databases and the general WordPress.org applications. They store your data on secure servers behind a firewall. The WordPress.org privacy policy is available here: https://wordpress.org/about/privacy/
  • Mailchimp (The Rocket Science Group, LLC), which we use to manage email marketing subscriber lists and send emails to our subscribers. Read their privacy policy here: https://mailchimp.com/en/legal/privacy/

3. Disclosure and sharing of information

As a matter of policy, FINOLOGEE does not sell, rent or provide in any form any of your information to third parties for any advertising or marketing purposes.

However, we may use external services such as Google Analytics for providing statistical and analytical services and process data on our behalf, without being allowed to share it with third parties.

4. Email Marketing

Under the GDPR we use the consent lawful basis for anyone subscribing to our newsletter or marketing mailing list. We only collect certain data about you, as detailed above. Any email marketing messages we send are done so through an EMS, email marketing service provider. An EMS is a third-party service provider of software / applications that allows marketers to send out email marketing campaigns to a list of users.

Email marketing messages that we send may contain tracking beacons / tracked clickable links or similar server technologies in order to track subscriber activity within email marketing messages. Where used, such marketing messages may record a range of data such as; times, dates, IP addresses, opens, clicks, forwards, geographic and demographic data. Such data, within its limitations will show the activity each subscriber made for that email campaign.

Any email marketing messages we send are in accordance with the GDPR. We provide you with an easy method to withdraw your consent (unsubscribe) or manage your preferences / the information we hold about you at any time.

Our EMS provider is Mailchimp. Mailchimp is an online marketing platform (the “Services”) operated by The Rocket Science Group LLC, a company headquartered in the State of Georgia in the United States.

The Services enable Members to, among other things, send and manage email campaigns and serve advertisements.

We hold the following information about you within our EMS system:

  • Information Mailchimp receives from us: your Email address
  • Information Mailchimp collects automatically: When you interact with an email campaign that you receive from us, Mailchimp may collect information about your device and interaction with an email. Mailchimp use cookies and other tracking technologies to collect some of this information.
  • Device information: Mailchimp collects information about the device and applications you use to access emails sent through our Services, such as your IP address, your operating system, your browser ID, and other information about your system and connection.
  • Product usage data: Mailchimp collects usage data about you whenever you interact with emails sent through the Services, which may include dates and times you access emails and your browsing activities (such as what pages are viewed). Mailchimp also collects information regarding the performance of the Services, including metrics related to the deliverability of emails and other electronic communications we send through the Services. This information allows Mailchimp to improve the content and operation of the Services, and facilitate research and analysis of the Services.

5. Your rights in relation to your Personal Data

Under the GDPR you have various rights as an individual which you can exercise under certain circumstances in relation to your Personal Data that we hold. These rights are to:

  • Request access to your Personal Data (commonly known as a “data subject access request”) and request certain information in relation to its processing;
  • Request rectification of your Personal Data;
  • Request the erasure of your Personal Data;
  • Request the restriction of processing of your Personal Data;
  • Object to the processing of your Personal Data

If you want to exercise one of these rights please contact us via info@finologee.com.

6. Security of your Personal Data

We are committed to take appropriate technical and organisational measures to protect your Personal Data against unauthorised or unlawful processing and against accidental loss, disclosure, destruction or damage.

Your Personal Data is stored in the European Union. Electronic files that contain Personal Data are stored within a highly secured IT infrastructure.

7. Retention period

We will only retain your Personal Data for as long as we need it in order to fulfil the purposes for which it was collected and processed, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements.

If you are a client, former client, interested party or prospective client or a contact person of one of the aforementioned, we store your Personal Data for marketing purposes until revocation or the revocation of your consent if the marketing measures were carried out based on your consent.

8. ’Cookies’

What is a cookie?

A cookie is a small piece of data or message that is sent from an organisation’s web server to your web browser and is then stored on your hard drive. Cookies can’t read data off your hard drive or cookie files created by other sites, and do not damage your system.

How do FINOLOGEE Site and services use cookies?

We only use cookies to monitor the performance of our website and to improve user experience. We use Google Analytics for this purpose. Analysis is performed on a purely anonymous basis. In our configuration, Google Analytics remarketing features are neither used nor enabled, and therefore we do not share any data with third parties. Google Analytics uses “cookies”, to help the website analyse how users use the websites, applications or services:

Google Universal Analytics

Cookie type
Google Universal Analytics

Purpose
This helps us count how many people visit https://www.finologee.com/by tracking if you have visited before

gat_

Cookie type
Google Universal Analytics

Purpose
Used to manage the rate at which page view requests are made

utma_

Cookie type
Google Analytics

Purpose
Used to determine new and returning visitors

utmb_

Cookie type
Google Analytics

Purpose
Used to determine the average time spent on the website

utmz_

Cookie type
Google Analytics

Purpose
Used to determine the traffic source, medium which delivered the user to our website

utmv_

Cookie type
Google Analytics

Purpose
Used to store visitor-level custom variable data

utmt_

Cookie type
Google Analytics

Purpose
Use to throttle request rate

The information generated by the cookie about your use of the websites, applications or services (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the websites, applications or services compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. 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.

You may refuse the use of cookies by selecting the appropriate settings on your browser or within the application, however please note that if you do this you may not be able to use the full functionality of this website. By using our website, applications or services you consent to the processing of data about you by Google in the manner and for the purposes set out above. To find out more, see “How Google uses data when you use our partners’ sites or apps”, (located at www.google.com/policies/privacy/partners/, or any other URL Google may provide from time to time).

To opt out of being tracked by Google Analytics across all websites visit: http://tools.google.com/dlpage/gaoptout

9. Change to this privacy notice & contact information

We reserve the right to modify this Privacy Policy at any time, so please review it regularly. If We make changes to this Privacy Policy, we will post the revised Privacy Policy on the Site. All such changes shall be binding on you 30 days after they are initially posted on the Site unless you are a new user, in which case they are binding on you immediately.

If you have questions or concerns regarding this Privacy Notice or you wish to exercise your rights in relation to your Personal Data, please do not hesitate to contact us at info@finologee.com or send your request to the following address:

FINOLOGEE S.A.
7, rue J. Fischbach,
L-3372 Leudelange,
Luxembourg